Draft 

 Quality Assurance Project Plan 

for Use of the Existing Data in EPA’s 

Screening-Level Analyses for Review of 

Industrial Discharges 

Prepared for: 

U.S. Environmental Protection Agency 

Engineering and Analysis Division 

Office of Water 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Prepared by: 

Eastern Research Group, Inc. 

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151-1102 

October 2011 

EPA Contract No. 68-C-02-095 

Work Assignment 9-05 
This page is intentionally blank 

 
TITLE AND APPROVAL SHEET

Quality Assurance Project Plan for Use of Existing Data in EPA’s Screening-Level 

Analyses for Review of Industrial Discharges 

10/24/2011 

Eleanor Codding - ERG Work Assignment Manager Date 

10/24/2011 

Mary Willet - ERG Project Quality Assurance Coordinator Date 

10/24/2011 

Deborah Bartram - ERG Program Manager Date 

Meghan Hessenauer - EPA Technical Project Officer (ERG Support Contract) Date 

William Swietlik - EPA Work Assignment Manager (ERG Support Contract) Date 

Samantha Lewis - EPA Alternate Work Assignment Manager (ERG Support Contract) Date 

Jan Goodwin - EPA Branch Chief, Technology and Statistics Branch Date 

Marion Kelly - EPA/EAD Quality Assurance Manager Date 

 
History of QAPP for Use of Existing Data in EPA’s Screening-Level Analyses for Review of 

Industrial Discharges

Revision 0 

Delivery Date October 24, 2011 

Work Assignment 9-05 

Scope Existing data for screening-level analyses 

Comments Received NA 

Comments Addressed NA 

Approval NA 

NA – Not yet received, addressed, or approved. 
Distribution 

This Quality Assurance Project Plan (QAPP) will be distributed to staff of the U.S. 

Environmental Protection Agency and Eastern Research Group, Inc. (Table 1). A copy of the 

document will be provided to all Eastern Research Group, Inc. staff involved in the project, 

including those who join the project after publication of the QAPP. 

Table 1. QAPP Distribution 

Name 

Title Contact Information Mailing Address 

U.S. Environmental Protection Agency 

Meghan Hessenauer 

Technical Project Officer 

(202) 566-1040 

Hessenauer.Meghan@epa.gov 

U.S. Environmental Protection Agency 

Office of Science and Technology 

1200 Pennsylvania Avenue, NW (4303T) 

Washington, DC 20460 

(202) 566-1053 (fax) 

Marion Kelly 

Quality Assurance Manger 

 (202) 566-1045 

Kelly.Marion@epa.gov 

William Swietlik 

Work Assignment Manager 

(202) 566-1129 

Swietlik.William@epa.gov 

Jan Goodwin 

Branch Chief 

(202) 566-1060 

Goodwin.Janet@epa.gov 

Eastern Research Group, Inc

Deborah Bartram 

ERG Program Manager 

(703) 633-1669 

Deborah.Bartram@erg.com 

Eastern Research Group, Inc. 

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151-1102 

(703) 263-7280 (fax) 

Mary Willett 

ERG Corporate Quality Assurance 

Manager and 

Project Quality Assurance Officer 

(703) 633-1615 

Mary.Willett@erg.com 

Eleanor Codding 

Work Assignment Manager 

(703) 633-1673 

Eleanor.Codding@erg.com 

Teresa Medley 

ERG Project Assistant 

(703) 633-1655 

Teresa.Medley@erg.com 

Elizabeth Sabol 

Task Lead 

(703) 633-1659 

Elizabeth.Sabol@erg.com 

Jessica Gray 

Chemical Engineer 

(703) 633-1681 

Jessica.Gray@erg.com 

Kimberly Landick 

Environmental Engineer 

(703) 633-1119 

Kimberly.Landick@erg.com 
i

CONTENTS 

Page 

1. INTRODUCTION .................................................................................................................... 1

2. PROJECT MANAGEMENT ...................................................................................................... 3

2.1 Project Organization and Responsibilities .............................................................. 3

2.2 Special Training and Certifications ........................................................................ 5

2.3 Project Records ....................................................................................................... 5

2.4 Assessment of QAPP Implementation .................................................................... 6

2.5 Project Status Reports for Management ................................................................. 7

3. PROJECT DESCRIPTION AND OBJECTIVES ............................................................................. 8

3.1 Problem Definition/Background ............................................................................. 8

3.2 Project Description .................................................................................................. 9

4. DATA NEEDS, SOURCES, AND QUALITY CRITERIA ............................................................. 10

4.1 Data Needs ............................................................................................................ 10

4.2 Data Sources ......................................................................................................... 10

4.2.1 Toxics Release Inventory (TRI) Expansion Sector Program Data 

Sources..... ................................................................................................ 10

4.2.2 Office of Chemical Safety and Pollution Prevention (OCSPP) and 

Office of Pollution Prevention and Toxic Substances (OPPTS) 

Program Data Sources............................................................................... 11

4.2.3 OAQPS Data Sources ............................................................................... 11

4.2.4 Office of Water Sewage Sludge Survey Data Sources ............................. 11

4.2.5 Additional Data Sources ........................................................................... 11

4.3 Data Quality Criteria and Specifications .............................................................. 12

4.3.1 Existing EPA Data Sources ...................................................................... 12

4.3.2 Existing Data Related to Environmental and Human Health Effects ....... 13

5. DATA ACQUISITION, REVIEW, QUALITY VERIFICATION, AND REPORTING ......................... 17

5.1 Data Acquisition and Documentation ................................................................... 17

5.2 Data Storage and Management ............................................................................. 17

5.3 Data Review .......................................................................................................... 18

5.4 Data Quality Verification ...................................................................................... 18

5.5 Data Quality Reporting ......................................................................................... 19

6. USE OF EXISTING DATA ..................................................................................................... 19

6.1 Data Summary or Analysis ................................................................................... 19

6.2 Technical Review of Data Analysis ...................................................................... 19

6.2.1 Methodology Documentation and Conceptual Review ............................ 19

6.2.2 Developmental Review ............................................................................. 20

6.2.3 Final Product Technical Review ............................................................... 20

6.3 Validation of Analysis Results.............................................................................. 20

6.4 Reconciliation with User Requirements ............................................................... 20

7. PROJECT REPORTS (DELIVERABLES) .................................................................................. 21
CONTENTS (Continued) 

Page 

ii

8. REFERENCES ...................................................................................................................... 21

Appendix A: PROJECT FILE MANAGEMENT PLAN 
iii

LIST OF TABLES 

Page 

Table 2-1. Reporting QA/QC Activities ..........................................................................................8

Table 3-1. Key Products and Milestones .......................................................................................10

Table 4-1. Data Sources Acceptance Criteria ................................................................................15

Table 7-1. Project Deliverables ......................................................................................................21
iv

LIST OF FIGURES 

Page 

Figure 2-1. Project-Level QA Organization for Existing Data Anlaysis .........................................4

Figure 5-1. Telephone Contact Report Form .................................................................................18
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Date: October 24, 2011 

Page 1 of 22

1. INTRODUCTION

Overview. EPA’s Engineering and Analysis Division (EAD) is conducting an annual 

review of existing effluent limitations guidelines and standards (ELGs) and identification of 

possible new ELGs. This review will be presented in the 2012 Final Effluent Guidelines 

Program Plan, to be published in 2012. Under Work Assignment 9-05 of Contract No. 68-C-02-

095, ERG is providing technical support to EPA in conducting its annual review of existing 

ELGs and identifying and evaluating new sources of wastewater discharges. This support 

includes evaluating facilities or categories based on the considerations contained in EPA’s 

Strategy for National Clean Water Industrial Regulations, namely those facilities or categories 

that discharge significant quantities of pollutants capable of causing water quality impairments or 

of impacting human health. EPA evaluates the relative hazard to human health and aquatic life 

using EPA-provided toxic weighting factors. EPA’s annual review includes these steps: 

1. Annual screening-level analysis to prioritize categories. 

2. Preliminary review of existing ELGs to investigate discharges from prioritized 

categories and to investigate stakeholder recommendations and comments. 

3. Detailed studies of prioritized ELGs to investigate pollutant sources and pollutant 

reduction approaches, to determine if EPA should identify prioritized categories 

for possible revision of their existing effluent limitations guidelines and/or 

pretreatment standards. 

4. Identification of potential new sources of wastewater discharges through 

evaluation of new data sources. 

 Under the Revised Quality Assurance Project Plan for the 2009 Annual Screening-Level 

Analysis of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data (September 2009), 

ERG conducts analyses for the first step. This Quality Assurance Project Plan (QAPP) covers the 

fourth step, identification of potential new sources of wastewater discharges. 

 Under previous work assignments, ERG prepared, and EPA approved three related 

QAPPs: 

 Quality Assurance Project Plan for the Screening Level Analysis of TRI and PCS 

Industrial Category Discharge Data (February 2004); 

 Quality Assurance Project Plan for the 2007 Annual Screening-Level Analysis of TRI and 

PCS Industrial Category Discharge Data (March 2007); and 

 Revised Quality Assurance Project Plan for the 2009 Annual Screening-Level Analysis 

of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data (September 2009). 

The previous QAPPs outline the quality assurance procedures for the annual screening-level 

analysis. This QAPP is a project-specific supplement to ERG’s corporate Quality Management 

Plan for Technical Support for the Strategy for National Clean Water Industrial Regulations,

June 2002 (QMP) (ERG, 2002) which was prepared in accordance with EPA Requirements for 

Quality Management Plans (U.S. EPA, 2001b). ERG’s QMP details the responsibilities of the 
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Page 2 of 22

ERG Quality Assurance (QA) coordinators and Project Management Team and describes 

procedures used to plan, implement, and assess project quality. ERG will use these procedures, 

tailored to the needs of the tasked activities, in the 2012 screening-level analysis of existing data 

sources. 

EPA’s Quality Guidelines. In response to guidelines issued by the Office of Management 

and Budget (OMB, 2002) under Section 515 of the Treasury and General Government 

Appropriations Act for Fiscal Year 2001 (Public Law 106-554; H.R. 5658), EPA developed 

Information Quality Guidelines (EPA, 2002) for ensuring and maximizing the quality of 

information disseminated by EPA. 

EPA’s Information Quality Guidelines defines quality as 

 Objectivity - information is accurate, reliable, and unbiased and its presentation is 

clear, complete, and unbiased; 

 Utility- information is useful for the intended users; and 

 Integrity - information is not compromised through corruption or falsification 

either by accident or by unauthorized access or revision. (from EPA, 2003, p. 9) 

In executing projects involving the collection and use of existing data, ERG will support 

EPA in meeting these guidelines by: 

 Understanding how EPA intends to use the collected data and collecting data 

appropriate for that use; 

 Working with EPA to develop specifications for the required accuracy, reliability, 

and objectivity of the data, evaluating collected data against those specifications, 

and including the results of these evaluations in intermediate and final project 

deliverables; and 

 Presenting the sources of data, assumptions made, and calculations used in all 

project deliverables. These identifications will be sufficiently detailed and 

transparent to ensure the reproducibility of the work by qualified third parties. 

QAPP Approval and Distribution. Each QAPP has a signed approval form, title page, 

table of contents, and EPA-approved document control format (see header at the top of each page 

in this QAPP). During the course of the project, the ERG WAM will circulate any revision to the 

approved QAPP to all ERG and EPA project staff. ERG will document the circulation of the 

revised QAPP to project staff with a signature page for the revision. 

History of this QAPP. As directed by Work Assignment 9-05, ERG prepared a detailed 

Quality Assurance Project Plan (QAPP) addressing the support it will provide for use of existing 

data in EPA’s screening-level analyses for review of industrial discharges. In previous years, as 

directed by Work Assignment 6-05, ERG prepared the Revised Quality Assurance Project Plan 

for the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial 

Category Discharge Data (September 2009). 

QAPP Organization. This QAPP is organized according to the work flow ERG uses for 

projects involving the collection and use of existing data. Although its organization differs from 
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Date: October 24, 2011 

Page 3 of 22

that presented in EPA Requirements for Quality Assurance Project Plans QA/R-5 (EPA, 2001b), 

it is responsive to all applicable elements of QA/R-5. The organization of this plan is as follows: 

 Section 2 Project Management 

 Section 3 Project Description and Objectives 

 Section 4 Data Needs, Sources, and Quality Criteria 

 Section 5 Data Acquisition, Review, Quality Verification, and Reporting 

 Section 6 Use of Existing Data 

 Section 7 Project Reports (Deliverables) 

 Section 8 References 

2. PROJECT MANAGEMENT

 This section addresses project management, including: 

 Project organization and responsibilities; 

 Special training and certification; 

 Project records; 

 Assessment of the implementation of this QAPP; and 

 Project status and quality activity reports to management. 

2.1 Project Organization and Responsibilities

Project organization for ERG’s collection and use of existing data for support of EPA’s 

industrial wastewater discharge review is depicted in Figure 2-1. The figure shows staff with 

program management and technical responsibilities and those with QA/QC roles. It also shows 

the relationship and lines of authority, reporting, and communication among all project 

participants, including those from EPA. 

The ERG Program Manager has overall responsibility for individual work assignments or 

directives. She organizes and directs the technical activities and functions as the primary liaison 

between EPA, ERG management, and the project team. Her responsibilities include: 

 Communicating with the EPA client on technical matters, the ERG Contract 

Administrator on contractual matters, and ensuring project staff follows the 

contract requirements; 

 Reviewing all work assignments, work plans, cost estimates, technical and 

financial progress reports, and invoices; 

 Working with the Project QA Coordinator and the ERG Work Assignment 

Manager (WAM) to resolve any quality problems that arise; and 

 Monitoring the technical activities on the work assignment to ensure that the 

technical objectives, budget, and schedule are met. 
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Figure 2-1. Project-Level QA Organization for Existing Data Anlaysis 

 The ERG WAM will be the principal contact for the EPA WAM on project issues, 

deliverables, and schedule. The ERG WAM will be responsible for: 

 Ensuring that the quality of work, schedule, and budget meet the requirements of 

the EPA effluent guidelines program; 

 Providing technical direction to ERG staff and managing the daily activities on 

the project; 

 Providing the official, approved QAPP to the ERG project team; 

 Obtaining appropriate technical review of all deliverables and ensuring 

deliverables conform to EPA’s technical review requirements; and 

ERG Corporate 

QA Manager 

ERG Project 

QA Coordinator 

ERG Technical 

Reviewers 

To be assigned

ERG Program 

Manager 

ERG Work 

Assignment 

Manager

ERG 

Task Lead 

ERG 

Staff 

EPA Project Officer 

EPA Work 

Assignment 

Manager

EPA 

QA Coordinator 

Lines of Communication 

Reporting and Authority
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Date: October 24, 2011 

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 Keeping the Project QA Coordinator and the Project Manager advised of any 

quality problems that arise. 

 ERG’s QA staff functions independently of the team collecting and analyzing data for 

this project. Ms. Mary Willet will serve as Project QA Coordinator, responsible for ensuring that 

the requirements of this QAPP are implemented and documented. Ms. Mary Willett also serves 

as ERG’s overall Corporate QA Manager and will ensure that project-specific QA/QC programs 

are commensurate with project objectives and with ERG’s quality system. 

 The EPA QA Coordinator is responsible for approving the QAPP and for retaining the 

official approved QAPP. The QAPP is not effective until approved and signed by the EPA QA 

Coordinator. 

2.2 Special Training and Certifications

The owners of the information may classify information and data collected during this 

project as Clean Water Act Confidential Business Information (CBI). Therefore, ERG will train 

project staff in CBI-handling procedures as outlined in ERG’s CBI security plans. ERG will 

permit only staff demonstrating their understanding of CBI handling procedures by passing a 

written test to access CBI on this project. ERG’s CBI Security Officer, Ms. Laurie Morgan, will 

maintain a list of all personnel cleared to access Clean Water Act CBI. The ERG WAM will 

confirm that project personnel are included on this list before they are permitted to access CBI. 

ERG will strictly adhere to all EPA procedures when handling industry CBI. ERG will 

manage all reports, documents, and other materials and all draft documents developed under this 

work assignment in accordance with the procedures set forth in ERG’s CBI security plan or its 

successor approved plan: 

 Security Plan for Handling Confidential Business Information Under the Clean 

Water Act, dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s 

Document Control Officer for this contract, on March 12, 2009. 

2.3 Project Records

ERG has developed and instituted document control mechanisms for the review, revision, 

and distribution of QAPPs. Each QAPP has a signed approval form, title page, table of contents, 

and EPA-approved document control format (see header at the top of each page in this QAPP). 

During the course of the project, the ERG WAM will circulate any revision to the approved 

QAPP to all ERG and EPA project staff. ERG will document the circulation of the revised QAPP 

to project staff with a signature page for the revision. 

ERG will handle and store all information collected, generated, and analyzed during this 

project in a centralized record. This centralized record contains all data collected or accessed 

from other sources and documents analyses of data collected (e.g., literature reviews and 

database analyses). During the period of performance, all project files, including interim or 

working files and final project deliverables, will be located and maintained on a computer at 

ERG’s facilities and will be backed up daily. Any files that contain CBI will be maintained on 

ERG’s secure CBI server. 
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 The ERG WAM is responsible for establishing and ensuring that version control is used 

for all project documents. Under this work assignment, the version of interim and working 

documents will be identified in the document and in the electronic file name using a sequential 

numbering or dating scheme. First versions may or may not have the version indicated as “v0.” 

Historical files will be kept and maintained in the project file. Final versions of documents will 

be identified in the electronic filename as “FINAL.” 

 At the conclusion of each year of the annual review, ERG will copy all docket files to a 

DVD disk and provide it to the EPA WAM. ERG will retain a copy of project electronic files in 

the ERG archive and will return paper materials to the EPA WAM, as directed. 

ERG’s WAM is responsible for designating an individual to maintain all project files, 

known as the index keeper. She is also responsible for ensuring that project team members 

document all data sources used. ERG is using a project file management plan for this project 

adapted from similar plans prepared for other work assignments on Contract No. 68-C-02-095. 

The plan provides detailed instructions for developing a project index using a Microsoft Office 

AccessTM database and a system to manage information collected on this project. This system is 

compatible with the needs of the Federal Docket Management System (FDMS). The ERG WAM 

has assigned the “index keeper” the responsibility of maintaining the file index and filing 

documents in the electronic project file. 

The 304m Project File Management Plan (Appendix A) includes detailed procedures for 

ensuring the quality of the project file and docket and for quality checks that will be performed 

during the assembly of the public and CBI dockets. 

2.4 Assessment of QAPP Implementation 

ERG will conduct several stages of review during the planning and execution of this 

project to assess that the procedures outlined in this QAPP are followed. All tasks conducted and 

products generated receive (1) a conceptual review, (2) a developmental review, and (3) a final 

product review. 

The ERG program manager and senior engineers with effluent guidelines knowledge who 

are not directly involved in the work assignment will provide a conceptual review during the 

initial stages of work development. This review will ensure that the final product and associated 

documentation address the needs set forth by the EPA WAM, the work assignment, and this 

QAPP. 

The quality of intermediate deliverables and final products is also evaluated as these 

work products evolve. This developmental review includes, for example, (1) checks on 

calculations and data quality and (2) reviews of draft documents to ensure that the direction of 

work is consistent with the conceptual review outline. 

ERG’s WAM will conduct a final product technical review of all deliverables prior to 

delivery to EPA. Technical review is a documented critical review of work that has been 

performed within the “state of the art.” In addition, reports and memoranda to the record will be 

reviewed by a senior-level engineer (for engineering activities) not directly involved with the 
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product. All deliverables will subsequently be reviewed by the EPA WAM. ERG will document 

all reviews of project deliverables in a deliverable review tracking spreadsheet. 

ERG’s Project QA Coordinator for this project or her designee will assess the 

implementation of QA/QC procedures on this project as follows: 

 Review the QAPP (this document) for completeness and applicability; and 

 Audit project files to ensure and verify the following: 

— That project staff have developed QC procedures and that these 

procedures are used; and 

— That project staff are documenting their use of these QC procedures by 

completing checklists, review spreadsheets, and other project-specific 

forms. 

 Any quality deficiencies detected by technical reviewers or the Project QA Coordinator 

will be communicated, in writing, to the ERG WAM. The ERG WAM is responsible for 

ensuring that appropriate corrective action is taken and reported to the Project QA Coordinator. 

The Project QA Coordinator will note if, at any time, she considers the project to have quality 

deficiencies that are not remedied in a timely manner. Upon noting that there are quality 

deficiencies, the Project QA Coordinator will conduct a project review as the ERG Corporate 

QA Manager. If the work is deficient, she will recommend to the ERG Program Manager that 

work related to these deficiencies be stopped until remedied. The ERG Program Manager will 

take necessary steps to resolve the issues with the ERG WAM and, if appropriate, will notify the 

EPA PO and/or WAM of actions taken. 

 ERG will include any reports of corrective actions in the project QA files. At any time or 

at the end of the project or work assignment, the Corporate QA Manager or her designee may 

inspect the project QA files. 

2.5 Project Status Reports for Management

Monthly, ERG will electronically submit to the EPA WAM and PO a progress report that 

documents the costs incurred and work performed during the previous accounting period and 

work planned for the current accounting period. 

Additionally, ERG will provide the EPA WAM with monthly reports on the status of 

quality assurance (QA) activities. These reports will be incorporated into our monthly technical 

progress reports which will be supplemented to include the following: 

 Quality assurance activities performed during the reporting period as part of the 

implementation of the work assignment; 

 Identification of any problems encountered; 

 Identification of any deviations from the QAPP; and 

 Identification of problem resolution and/or corrective actions taken during the 

reporting period, if any. 

Table 2-1 lists the type of QA/QC activities that ERG will report to the EPA WAM. 
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Table 2-1. Reporting QA/QC Activities

Data Generation, 

Acquisition, and Use QA/QC Activities that ERG will report to EPA in the monthly QA activity report 

Existing Data 

Collection 

Evaluate the quality of data using data acceptance criteria. 

Follow set procedures when collecting published data or data from telephone/email 

contacts. 

Submit project data and publications to the project file index keeper. 

Verify that data sources have been correctly entered into the project file index. 

Perform a conceptual review, a developmental review, and a final product review on all 

technical memoranda. 

ERG will describe QA activities conducted for major deliverables, such as summary 

memoranda, when such documents are delivered to EPA. These descriptions may be included in 

the document or in the transmittal email, as directed by EPA. 

3. PROJECT DESCRIPTION AND OBJECTIVES

This section provides a management-level overview of the project and its objectives. That 

is, this section focuses on the purpose of the project. Planned execution of the project is detailed 

in the following sections: 

 Section 4 describes the data needed to answer the questions and problem 

presented in Section 3; 

 Section 5 describes how ERG will obtain, check, and store collected data; 

 Section 6 describes how ERG will use the data by developing data summaries or 

engineering analyses; and 

 Section 7 describes the project deliverables. 

3.1 Problem Definition/Background

 ERG’s analysis of existing data sources will provide technical support to EPA for their 

preparation of the 2012 Final Effluent Guidelines Program Plan required by CWA Section 

304(m). The key elements in the 2012 Final Effluent Guidelines Program Plan are as follows: 

 Annual review of effluent guidelines and pretreatment standards that EPA has 

promulgated under the CWA; 

 Identification of categories of sources discharging toxic or nonconventional 

pollutants for which guidelines or pretreatment standards have not previously 

been published; and 

 Establishing a schedule for further investigation and/or possible development or 

revision of effluent guidelines and pretreatment standards. 
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To prepare its 2012 Final Effluent Guidelines Program Plan, EPA will seek to answer, among 

others, the following questions: 

 What industrial wastewater discharges pose the greatest potential threat to 

human health or the environment?

 What industrial wastewater discharges should be studied further?

 What industrial wastewater discharges warrant possible ELG development or 

revision? 

ERG’s analysis of existing data sources will support EPA in answering these questions. 

3.2 Project Description

 Previous screening-level analyses. On earlier work assignments, ERG supported EPA’s 

development of the 2004, 2006, 2008, and 2010 Effluent Guidelines Program Plans. This support 

included developing nine databases of TRI reported releases (TRIReleases2000, 

TRIReleases2002, TRIReleases2003, TRIReleases2004, TRIReleases2005, TRIReleases2006, 

TRIReleases2007, TRIReleases2008, and TRIReleases2009) and six databases of discharge 

monitoring report (DMR) discharges (PCSLoads2000, PCSLoads2002, PCSLoads2004, 

DMRLoads2007, DMRLoads2008, and DMRLoads2009). The following documents describe the 

development of these databases: 

 Technical Support Document for the 2004 Effluent Guidelines Program Plan 

(U.S. EPA, 2004); 

 2005 Annual Screening-Level Analysis: Supporting the Annual Review of Existing 

Effluent Limitations Guidelines and Standards and Identification of New Point 

Source Categories for Effluent Limitations and Standards (U.S. EPA, 2005); 

 Technical Support Document for the 2006 Effluent Guidelines Program Plan 

(U.S. EPA, 2006a); 

 Technical Support Document for the Preliminary 2008 Effluent Guidelines 

Program Plan (U.S. EPA, 2007); 

 Technical Support Document for the 2008 Effluent Guidelines Program Plan 

(U.S. EPA, 2008); 

 Technical Support Document for the Preliminary 2010 Effluent Guidelines 

Program Plan (U.S. EPA, 2009); and 

 Technical Support Document for the 2010 Effluent Guidelines Program Plan 

(U.S. EPA, 2010). 
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 ERG’s support for the 2012 Final Effluent Guidelines Program Plan will build on the 

work from the previous screening-level analyses by including new data sources. 

The key products ERG will produce and key milestones are listed in Table 3-1. 

Table 3-1. Key Products and Milestones 

Key products and milestones Date 

Five technical approach memoranda, initial draft October 31, 2011 or as directed by EPA 

WAM 

Five technical approach memoranda, final draft November 30, 2011 or as directed by 

EPA WAM 

Draft report sections documenting findings May 2012 or as directed by EPA WAM 

All documents drafted to support EPA’s Final 2012 

Plan 

Concurrent with EPA’s draft Final 

2012 Plan projected date (August 2012)

All documents finalized to support EPA’s Final 2012 

Plan 

Concurrent with EPA’s Final 2012 Plan 

projected publication date (September 

2012) 

4. DATA NEEDS, SOURCES, AND QUALITY CRITERIA

This section discusses the data needed to answer the key questions listed in Section 3.1 

and describes the sources that ERG will review to identify these data. 

4.1 Data Needs

To answer the key questions to support the existing data screening-level analyses in 

preparation of the 2012 Final Effluent Guidelines Program Plan, EPA needs data characterizing 

industrial wastewater discharges and related treatment residues, and data identifying the sources 

of the wastewater. 

4.2 Data Sources

This section provides general descriptions of the data sources that ERG will use for this 

project. Quality criteria and specifications for the collected data are discussed in Section 4.3. 

Section 5.1 provides additional details of how data will be collected and documented. ERG will 

obtain the existing data from employees and publications/databases available from other EPA 

offices, www.regulations.gov, and other websites. 

4.2.1 Toxics Release Inventory (TRI) Expansion Sector Program Data Sources 

 ERG will review data collected on Industrial Laundries, which were collected as part of 

the TRI Program’s consideration of expansion sectors. ERG will consider these data in concert 

with existing data, such as data from EPA’s 1999 Final Action on Industrial Laundries ELGs, 

which resulted in no rulemaking. 
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4.2.2 Office of Chemical Safety and Pollution Prevention (OCSPP) and Office of Pollution 

Prevention and Toxic Substances (OPPTS) Program Data Sources 

 ERG will screen the latest publications from the OCSPP/OPPTS Programs for new 

industry categories or potential new pollutants of concern not currently regulated. These 

publications will include the High Production Volume (HPV) Program, Significant New Use 

Rules (SNUR), and the Inventory Update Rule (IUR). 

4.2.3 Office of Air Quality Planning and Standards (OAQPS) Data Sources 

 ERG will review the recent air emission rules to determine any trends in wet air pollution 

control and resulting wastewater. These reviews will include rules from the National Emission 

Standards for Hazardous Air Pollutants (NESHAPs)/Maximum Achievable Control Technology 

(MACT), New Source Performance Standards (NSPS), New Source Review (NSR)/Prevention 

of Significant Deterioration (PSD), and other air programs. 

 

4.2.4 Office of Water Sewage Sludge Survey Data Sources 

 ERG will examine the Office of Water’s Targeted National Sewage Sludge Survey 

(TNSSS) for pollutants of concern associated with industrial activity, including examining recent 

contamination issues associated with the beneficial reuse of biosolids, such as, perfluorinated 

chemicals. 

4.2.5 Additional Data Sources 

 ERG will evaluate the possible use of the following data sources to identify any 

alternative investigation categories: 

 Data from EPA’s WATERS program (http://www.epa.gov/waters/): 

o Clean Water Act Section 303d data for impaired waters, for impairments 

resulting from industry discharges. Specifically looking at TMDLs for 

pollutants such as pathogens, metals other than mercury, mercury, nutrients, 

and sediments. 

o Newly-developed water quality criteria. 

o Fish consumption advisories to identify pollutants most commonly triggering 

advisories. 

o High priority targeted watersheds for industrial impacts, such as those in the 

National Estuary Program. 

 OECA enforcement initiatives described in spreadsheets, databases, or reports of 

sector information. 

 Emerging drinking water and groundwater contamination problems that may be 

caused by industry by reviewing current Office of Groundwater and Drinking 
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Water (OGWDW) priorities and data warehouses and publications from the U.S. 

Geological Survey. 

 New analytical methods that would better characterize contamination problems 

not currently identified in the screening-level databases. 

 Reports of new, more effective wastewater treatment technologies for an existing 

industry category, including review of public comments and technical conference 

material to identify new technologies. 

 Environmental Justice (EJ) areas developed using zip code and/or GIS polygons. 

 Data received during outreach to industry and non-governmental stakeholders, as 

well as EPA Region, state, and local organizations. 

4.3 Data Quality Criteria and Specifications

The primary objectives of this QAPP are to ensure that: 

1. Data generated and collected are of the quality necessary for EPA to 

identify industrial wastewater discharges not currently regulated; and 

2. The results of the analyses of these data are documented and of the type, 

quality, transparency, and reproducibility needed. 

Measures and descriptions of data quality criteria that ERG will use to identify data that 

are fit for this use are described in this section. ERG will collect information about industrial 

wastewater discharges from existing data sources. ERG anticipates collecting data on: 

 Industrial sector products and pollution control trends. 

 Wastewater characteristics. 

 Treatment technology performance/efficiency. 

 Pollutant loads discharged by industry, facility, and pollutant. 

 Treatment technology costs. 

 Environmental and human health effects. 

The criteria ERG will use to evaluate the quality of information collected on these topics 

are summarized in Table 4-1, along with acceptable values for each criterion. ERG will describe 

data quality in the QA section of monthly technical progress reports, and as needed in emails that 

accompany deliverables. 

4.3.1 Existing EPA Data Sources 

Table 4-1 lists the data sources acceptance criteria by type of use in relationship to the 

type of data. Existing data sources will include discharge data (e.g., data received during 

stakeholder outreach and databases from other EPA offices such as IUR and WATERS), articles 
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and technical papers, industry/vendor data, and internet information. Table 4-1 provides the 

specific circumstances that define when data meet acceptance criteria or when data are unusable. 

 When existing data are received, ERG will use the criteria in Table 4-1 to identify if the 

data are usable for this program. In addition to the criteria listed in Table 4-1, ERG will evaluate 

the reasonableness of existing data. For example, pollutants must be reasonably related to the 

process or waste stream from which they were discharged. ERG may flag data sets as 

questionable and subject to further investigation if a chemical is detected that is not expected in 

the waste stream or if an expected chemical is missing (based on historical data from earlier 

annual reviews, such as the DMRLoads and TRIReleases databases described in Section 3.2). 

ERG will communicate to the EPA WAM whether reported or calculated pollutant loads, plant 

wastewater flows, or other existing data reflect the range of expected values. In addition, if the 

data provided by a data source are repeatedly found to be unreasonable, ERG will communicate 

these quality issues to EPA and wait for further direction from the EPA WAM. 

 ERG will not review the quality of existing data contained in published EPA databases 

and data systems (e.g., WATERS) or other databases provided by federal or state agencies or 

trade organizations but will describe known limitations of the data in reports on which they are 

based. If ERG identifies limitations in the quality of the data from published literature or 

federal/state generated databases that may impact decisions regarding the overall direction of 

further data collection efforts or the quality of deliverables, ERG will communicate these issues 

to the EPA WAM. Data limitation discussions will identify where data gaps exist and a 

description of data reporting requirements. 

4.3.2 Existing Data Related to Environmental and Human Health Effects 

 In addition to the analyses listed in Table 4-1, ERG will also use existing data to support 

qualitative assessments of the impact of industrial discharges on the environment. These analyses 

will likely rely on published literature identified during review of materials related to the targeted 

analyses. The criteria that ERG will use to evaluate the quality of literature are 1) accuracy, 2) 

reliability, and 3) representativeness. 

Accuracy. ERG assumes that the underlying data and information contained in state and 

federal reports and peer-reviewed journal articles are accurate. ERG assumes that data from these 

sources are of sufficient quality to identify potential environmental impacts associated with 

industrial discharges. ERG will present data that are outliers (e.g., data that are not consistent 

with the body of information collected from the literature review) to EPA for further direction on 

how to incorporate or exclude the data in the analysis. 

Reliability. During the review of existing literature, ERG may encounter sources that 

contain limited documentation of the environmental impact claim (e.g., unidentified speaker at a 

stakeholder meeting or a local resident commenting in a newspaper article). These data sources 

represent a lower level of reliability than peer-reviewed literature, but may provide useful 

information for capturing the full range of environmental impacts associated with industrial 

discharges. If ERG identifies limitations in the quality of information taken from other existing 

data sources (e.g., web sites, newspapers, and stakeholder meetings), ERG will communicate 

these data quality issues to EPA. ERG will also evaluate existing data for use in qualitative 

analyses for reliability based on the following factors: 
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 The scientific work is clearly written, so that all assumptions and methodologies 

can be identified; 

 The variability and uncertainty (quantitative and qualitative) in the information or 

in the procedures, measures, methods, or models are evaluated and characterized; 

and 

 The assumptions and methodologies are consistently applied throughout the 

analysis as reported in the source. 

Representativeness. ERG will evaluate existing data for use in qualitative analyses for 

representativeness based on whether they represent: 

1) The types of environmental impacts caused by wastewater discharges. 

2) The range of concentrations. 

3) The environments affected (e.g., rivers, lakes, and wetlands). 

 

 
Table 4-1. Data Sources Acceptance Criteria 

Type of Data Data Not Usable 

Data Usable for 

Industrial Sector 

Trends 

Data Usable to 

Characterize 

Wastewater 

Data Usable to 

Demonstrate System 

Performance/Efficiency 

Data Usable to 

Estimate 

Pollutant Loads

Data Usable 

Estimate Co

Treatmen

Discharge Data (e.g., Databases from other EPA offices such as WATERS) 

(1) Data collected by an unknown method or units undefined. (2) Data collected during upset conditions. (3) Represents a process that is not of interest (e.g., sanitary wastewater). 

Waste stream identified and analytes identified. 

Waste stream identified and analytes, units, and detection limits identified. 

(1) Represents full-scale system. (2) Paired influent and effluent data shows that treatment system is welldesigned and operated. (3) Analytes identified and units included. 

Identified as discharge, analytes identified and units provided, approved analytical method used, represent current treatment operations. 

Data not typically used this purpose. 

Articles/ Technical Papers 

Information does not address key questions 

Documented and reputable sources found through literature searches (e.g., peerreviewed journals and government publications). 

Waste stream identified and analytes, units, and detection limits identified. 

(1) Represents full-scale system. (2) Paired influent and effluent data shows that treatment system is welldesigned and operated. (3) Data do not represent upset conditions. (4) Analytes identified and units and detection limits included. 

Identified as discharge, analytes identified and units provided, approved analytical method used, represent treatment operations. 

Cost componfully defined identified (e.gdirect and indirect capitannual operatand maintenance)cost year identified. 
Table 4-1. Data Sources Acceptance Criteria 

Type of Data Data Not Usable 

Data Usable for 

Industrial Sector 

Trends 

Data Usable to 

Characterize 

Wastewater 

Data Usable to 

Demonstrate System 

Performance/Efficiency 

Data Usable to 

Estimate 

Pollutant Loads

Data Usable 

Estimate Co

Treatmen

Industry/ Vendor Data 

Information does not address key questions. 

These data are generally acceptable for relevant sources. 

Data not typically used for this purpose. 

(1) Represents full-scale system. (2) Paired influent and effluent data shows that treatment system is welldesigned and operated. (3) Data do not represent upset conditions. (4) Analytes identified and units and detection limits included. 

Data not typically used for this purpose. 

Cost componfully defined identified (e.gdirect and indirect capitannual operatand maintenance)cost year identified. 

Internet Information (not published articles or technical papers) 

Information does not address key questions. 

These data are generally acceptable for relevant sources. 

Data not typically used for this purpose. 

Data not typically used for this purpose. 

Data not typically used for this purpose. 

Data not typically used this purpose. 
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5. DATA ACQUISITION, REVIEW, QUALITY VERIFICATION, AND REPORTING

This section describes how ERG will acquire the data needed to answer the key questions 

listed in Section 3.1, describes how ERG will determine if the data meet the specifications listed 

in Section 4, and how this determination will be documented. The use of these existing data 

sources is described in Section 6. 

5.1 Data Acquisition and Documentation

ERG will obtain data from sources such as employees and publications/databases 

available from other EPA offices, government publications, and scientific literature. 

ERG staff will use the following procedures when collecting published data: 

 ERG researchers will collect full bibliographic information on all collected 

publications, including “date accessed” for information collected from the 

Internet. 

 ERG researchers will save Web pages as PDF files, so that the data source can be 

added to the electronic project file. 

ERG staff will use the following procedures when collecting data via telephone and email 

contact. 

 ERG researchers will document all telephone contacts using the Telephone 

Contact Report depicted in Figure 5-1. 

 ERG researchers will save all email contacts as pdf files, so that they can be 

added to the electronic project file. 

 ERG researchers will ensure that telephone contact reports and email records are 

added to the electronic project file. 

ERG will notify EPA of any data quality limitations during weekly meetings or via email. 

ERG will follow EPA WAM direction on which data to include or exclude in the technical 

review of existing sources for the 2012 Final Effluent Guidelines Program Plan. 

5.2 Data Storage and Management

ERG researchers will submit publications and meta data to the project file index keeper. 

The index keeper will add meta data describing the publications to the 304m Project File Index. 

Following the procedures detailed in the project file management plan, the index keeper will add 

the publication file to the 304m Electronic Project File. 
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Figure 5-1. Telephone Contact Report Form 

5.3 Data Review

According to EPA’s Guidance for QAPPs (QA/G-5), data review is “the in-house 

examination to ensure that the data have been recorded, transmitted, and processed correctly. 

That includes, for example, checking for data entry, transcription, calculation, and reduction 

errors...It is a completeness check to determine if there are any deficiencies, such as data 

missing....” 

After acquiring existing data, ERG will ensure that the documentation for these data 

sources has been correctly entered into the project file index. ERG will also ensure that the data 

meet the acceptance criteria in Table 4-1. Information added to the project file will be checked as 

described in the Project File Management Plan, which includes periodic project file review and 

project file reviews conducted during docket assembly. 

5.4 Data Quality Verification

According to EPA’s Guidance for QAPPs (QA/G-5), data verification is “the process of 

evaluating the completeness, correctness, and conformance of a specific data set against the 

method, procedural or contractual specifications.” For this project, data verification means the 

process in which ERG will determine if collected data meet the data acceptance criteria specified 

in Section 4.3. To accomplish this, ERG will check the data source and/or data itself against the 

quality criteria of Table 4-1. ERG will also document if any data or data sources do not meet the 

criteria. 

Project No.: DISTRIBUTION 

Page 1 of 1 

 Project Name: 

TELEPHONE CALL 

RECORD 

 Outgoing Call 

Date: Time: 

Company Name: Contact Name: 

Phone No.: 

Name: 

GENERAL SUBJECT : 

TOPICS DISCUSSED AND ACTION TAKEN 
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ERG may use data that do not meet the specifications if, for example, there are no other 

available data. ERG will discuss such data quality issues with the EPA WAM and obtain his 

written approval before using these data in subsequent analyses. This approval will be added to 

the project quality file. In its final project report, ERG will describe data quality, including any 

need to use data that did not meet quality acceptance specifications. 

5.5 Data Quality Reporting

 As discussed in Section 2.5, ERG will provide the ERG WAM with a monthly report of 

the status of QA activities. ERG will describe data quality, including any need to use data that 

did not meet quality acceptance specifications, in its final project report. 

6. USE OF EXISTING DATA

 ERG will use the collected data to compile industrial discharge data for EPA. ERG will 

follow EPA WAM direction for using the collected data to supplement the annual screeninglevel analysis. If any calculations occur, an ERG technical reviewer will verify that any 

calculations performed reflect the technical approach and that original data are correctly input 

into the spreadsheet. 

6.1 Data Summary or Analysis

 ERG will review the data sources to determine if additional consideration is needed. 

Examples of data needing additional consideration include discharge data from one year to the 

next year showing significant increases or new technologies identified for an industry sector that 

were not considered in previous ELG rulemakings. If data meet the quality criteria, listed in 

Table 4-1, ERG will discuss findings with the EPA WAM during weekly status calls. At the 

direction of the EPA WAM, ERG will summarize the relevant data in memoranda or draft report 

sections for EPA’s review.

6.2 Technical Review of Data Analysis

Related to the use of existing data in EPA’s annual review, process, ERG will prepare 

memoranda that describe the technical approach to ERG’s analysis of existing data for EPA’s 

review. ERG will follow the prescribed approach once approved by the EPA WAM, reporting 

findings during weekly meetings. As directed by the EPA WAM, ERG will then summarize 

findings in report sections or additional memoranda. 

The memoranda ERG develops for this project will document the data sources and 

describe how the data will be used in support of the screening-level analysis. They will receive 

(1) a conceptual review, (2) a developmental review, and (3) a final product review. 

6.2.1 Methodology Documentation and Conceptual Review 

ERG will set up a technical approach in memoranda for EPA review. ERG senior 

engineers knowledgeable in the development of ELGs, but not directly involved in the work 

assignment, and the ERG program manager will review these approach memoranda; that is, they 
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will provide conceptual review. Their review will ensure that the planned discussion will address 

the needs set forth by the EPA WAM and the work assignment. The ERG WAM will discuss 

conceptual review findings with the EPA WAM before the memoranda are completed during 

weekly meetings. 

6.2.2 Developmental Review 

An ERG technical reviewer will verify that any calculations performed reflect the 

technical approach and that original data are correctly input into any spreadsheets or databases. 

ERG will use standard engineering references to document that calculations are appropriate. 

ERG will review any constants used for appropriateness, will check that units are converted 

properly, and will document and check the equations used in the costing spreadsheets. The 

spreadsheet reviewer will provide the spreadsheet developer with a written summary of the data 

checked, any errors or problems found, and any recommendations for revisions. 

6.2.3 Final Product Technical Review 

ERG will summarize findings of targeted review methodologies in memoranda or reports 

for EPA WAM review. A senior-level engineer not directly involved with the project will review 

the final report. ERG will document this review and record it in the deliverable review 

spreadsheet in the project QA files. 

6.3 Validation of Analysis Results

 According to EPA’s Guidance for QAPPs (QA/G-5), data validation is “an analyte- and 

sample-specific process that extends the evaluation of data beyond method, procedural, or 

contractual compliance (i.e., data verification) to determine the analytical quality of a specific 

data set.” 

 ERG will support EPA in validating the results of the data summaries by using 

engineering judgment to evaluate whether the estimates “make sense” in the context of our 

knowledge of industrial wastewater discharges. This evaluation may include analysis of the 

results, for example toxic weighting factors. ERG will investigate the input data and assumptions 

and use engineering judgment to understand whether the result is logical. 

6.4 Reconciliation with User Requirements

ERG will identify the sources of data, assumptions made, and calculations used in our 

development in all project deliverables. These identifications will be sufficiently detailed and 

transparent to ensure the reproducibility of the work by qualified third parties. 

ERG will include an evaluation of data and data analysis quality in all project 

deliverables and during weekly meetings. Any limitations of the data and data analyses will be 

described in all project deliverables, but EPA will decide how to use the data and data analyses. 

ERG will compare findings to known values to verify results, including overall industry 

trends, pollutant loadings, and geographic scope. For example, ERG will use results from 

previous years’ findings, including published screening-level databases, the TRIReleases and 
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DMRLoads databases and the most recent Preliminary and/or Final ELG Plans described in 

Section 3.2 of this QAPP. Additionally, ERG will report how well the data collected and 

analyzed for this project answer the key questions identified in Section 3.1 of this QAPP. 

7. PROJECT REPORTS (DELIVERABLES)

The key products ERG will produce and how data quality will be reported in each are 

listed in Table 7-1. 

Table 7-1. Project Deliverables

Key products Data Quality Report Content 

Five Technical Memoranda  The ERG WAM will discuss memoranda conceptual review findings with 

the EPA WAM. 

2012 Final Plan  Supporting documentation as directed by the EPA WAM: additional 

memoranda or report section. Documentation will assess how well project 

collected and analyzed data answer the key questions. 

 Executive summary will discuss limitations of the collected data. 

8. REFERENCES

EPA, 2001. U.S. Environmental Protection Agency. EPA Requirements for Quality Assurance 

Project Plans QA/R-5. EPA/240/B-01/003. Office of Environmental Information. March 2001. 

EPA, 2002. U.S. Environmental Protection Agency. Guidance for Quality Assurance Project 

Plans QA/G-5. EPA/240/R-02/009. Office of Environmental Information. March 2001. 

EPA, 2002. U.S. Environmental Protection Agency. Guidelines for Ensuring and Maximizing the 

Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental 

Protection Agency. EPA/260R-02-008. October 2002. 

EPA, 2003 U.S. Environmental Protection Agency. A Summary of General Assessment Factors 

for Evaluating the Quality of Scientific and Technical Information, EPA 100/B-03/001. June, 

2003. 

OMB, 2002. U.S. Office of Management and Budget. Guidelines for Ensuring and Maximizing 

the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies 

(67 FR 8452).
Appendix A 

304M PROJECT FILE MANAGEMENT PLAN 
304m Project File 

Management Plan 

Prepared for:

U.S. Environmental Protection Agency

Engineering and Analysis Division 

Office of Water 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Prepared by: 

Eastern Research Group, Inc.

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151 

24 March 2003 

Revised 05 March 2004 

Revised 01 December 2004 

Revised 30 March 2006 

Revised 18 July 2006 

Revised 30 April 2007 

Revised 7 March 2008 

Revised 15 August 2008 

Revised 19 December 2008 

Revised 26 June 2009 

EPA Contract No. 68-C02-095 

Work Assignment 6-05
USE AND DISCLOSURE OF DATA

The data contained herein must be treated as privileged and confidential. As such, the contents of 

this document shall not be duplicated, used, or disclosed in whole or in part without the 

permission of Eastern Research Group, Inc. for any purpose other than to evaluate this project 

file management plan. The entire contents of this plan are subject to this restriction. 
i

TABLE OF CONTENTS 

Page 

1.0 INTRODUCTION AND DEFINITIONS .............................................................................1-1 

1.1 Background ..................................................................................................................1-1 

1.2 304m Project File.............................................................................................................1-2 

1.3 Docket ..................................................................................................................1-3 

1.4 Federal Docket Management System (FDMS)................................................................1-3 

1.5 Electronic Project File......................................................................................................1-4 

1.6 Contract File ..................................................................................................................1-4 

1.7 Personal Files ..................................................................................................................1-4 

1.8 Project File Index.............................................................................................................1-4 

1.9 FDMS Metadata...............................................................................................................1-4 

1.10 Confidential Business Information (CBI)........................................................................1-5 

1.11 CBI-Deducible Information.............................................................................................1-5 

2.0 GENERAL PROCEDURES ....................................................................................................2-1 

2.1 Submitting Material to the Project File............................................................................2-1 

2.1.1 Step-By-Step Process for Submitting Project File Materials...........................................2-1 

2.1.2 Detailed Discussion of Document Submission Process...................................................2-9 

2.2 Document Control Numbers (DCNs) ............................................................................2-11

2.2.1 Appendices........................................................................................2-11

2.2.2 Copies............................. ......................................................................................2-11 

2.2.3 CBI Documents........................................................................................................2-11 

2.3 Project File Index...........................................................................................................2-11 

2.3.1 Index Structure.........................................................................................................2-11

3.0 QUALITY CONTROL PROCEDURES.....................................................................................3-1 

3.1 Responsibilities................................................................................................................3-1 

3.2 Project File Quality Review Procedures..........................................................................3-1 

3.2.1 Project File Index........................................................................................................3-2 

3.2.2 Project File and Filing Review ........................................................................................3-2

3.2.3 Project File Revision Plan..... ..........................................................................................3-3 

4.0 DOCKET ASSEMBLY..........................................................................................................4-1 

Attachment 1 PROJECT FILE OUTLINE 

Attachment 2 304m PROJECT FILE LOG-IN FORM 

Attachment 3 FDMS GUIDELINES FOR FREE TEXT FIELDS 
1-1

1.0 INTRODUCTION AND DEFINITIONS

 This document is a plan for the preparation of the project file for EPA’s evaluation of 

categories of industrial dischargers for potential national regulations. ERG is supporting 

this work through a series of work assignments on the National Strategy contract (EPA 

Contract No. 68-C02-095). Because EPA’s activities are, in part, required by Clean 

Water Act Section 304(m), the project files are referred to as the 304m project files. This 

project file management plan is a living document and will be revised and reissued, as 

necessary. This plan includes definitions and procedures so that all 304m project team 

members will have the same understanding of our file system. The definitions and 

procedures are project-specific and may differ from terms used for other regulatory 

development work. 

 All project file materials will be managed according to ERG’s EPA-approved 

Confidential Business Information (CBI) security plan that describes the procedures we 

will use to handle CBI on this contract. All 304m team members will be trained and 

tested in CBI procedures before they are permitted to access CBI. 

1.1 Background

 ERG is supporting EPA in the development and implementation of a strategy for 

National Clean Water Industrial Regulations. This National Strategy sets out how EPA 

will fulfill the responsibilities of Section 304(m) and Section 304(g) of the Clean Water 

Act. The 1972 Clean Water Act directs EPA to develop national regulations placing 

limits on the pollutants that are discharged by categories of industry to rivers and streams 

(termed “effluent guidelines”) or to sewage treatment plants1

 (termed “pretreatment 

standards”). The Act also directs EPA to develop national regulations for new industrial 

facilities (termed “new source performance standards”). 

 An additional critical component of the Act is that it requires EPA to periodically study 

and review existing effluent guidelines, pretreatment standards, and new source 

performance standards and consider the need to develop regulations for industries not 

covered by a national regulation. These planning requirements are found in several 

sections of the Clean Water Act (CWA). Section 304(m) provides for an effluent 

guidelines plan to be published on February 4, 1987 and biennially thereafter. Each 

effluent limitations guidelines (ELG) plan contains three basic elements. 

 First, EPA must establish a schedule for the annual review of existing effluent guidelines 

promulgated under Section 304(b) (i.e., limitations for existing direct dischargers) and for 

revision of the guidelines if appropriate (see Section 304(m)(1)(A)). Second, EPA must 

identify categories of sources that directly discharge toxic or non-conventional pollutants 

for which EPA has not published effluent limitations guidelines or new source 

performance standards (see Section 304(m)(1)(B)). Third, EPA must establish a schedule 

for the establishment of national regulations for any categories identified in the second 

step, with a promulgated regulation after identification in a national plan (see Section 

304(m)(1)(C)). 

 

1

 Also referred to as publicly owned treatment works or POTWs. 
1-2

 For indirect dischargers, Section 304(g) requires EPA to review at least annually and, if 

appropriate, revise the pretreatment standards EPA has promulgated under Section 307 of 

the Clean Water Act. In addition, Section 307(c) provides that pretreatment standards are 

to be established at the same time as effluent guidelines for a given industry. 

 ERG will support the Agency in conducting its annual reviews, developing its biennial 

ELG plans, and conducting related studies of categories of wastewater dischargers. Some 

of these studies may result in EPA’s selection of that category for further action. These 

actions may include rulemaking efforts, voluntary programs, and/or further study. 

 ERG’s support includes collecting information from existing databases, technical 

publications, and other sources. ERG will also support EPA by analyzing this 

information. The documents, references, and other materials assembled by ERG comprise 

the 304m project file. 

 One of EPA’s overarching goals for this work is to provide transparent decision-making. 

This means that the information EPA uses to develop the biennial ELG plans, choose 

categories for review, and select appropriate further actions, will be made available to the 

public (with the exception of Confidential Business Information, discussed later in this 

plan). As EPA announces its actions in the Federal Register, ERG will support EPA 

in preparing an official docket for the action from the materials assembled in the 

304m project file (see Section 4).

1.2 304m Project File

 The 304m project file will contain items that are collected or developed during the 

support of EPA’s annual reviews, category reviews, detailed studies and ELG plan 

development. These items may include: 

 Meeting minutes; 

 Summaries and transcripts of public meetings and hearings; 

 Records of communications with parties outside of EPA, including telephone 

calls, memoranda, and letters; 

 Public statements made by EPA employees in their official capacities; 

 Public comments, including written opinions, data, and other information; 

 Items submitted to EPA that agree, disagree, and/or suggest alternatives to the 

proposed action; and 

 Bibliographies of materials to possibly add to the 304m Docket. 

The project file may also contain certain material that would not be appropriate for 

inclusion in public dockets, such as: 

 Internal briefing packages; 

 “Deliberative” items, including memoranda from ERG to EPA that present 

regulatory alternatives; 
1-3

 Drafts of Site Visit Reports and Sampling Episode Reports with affected facility 

review comments (where only the final version is placed in the public docket); 

 EPA Work Group briefing materials and reports; 

 EPA management briefing materials; 

 EPA internal transmittal memoranda for the rulemaking package; 

 Other internal EPA communications; and 

 Memoranda from ERG to EPA that set out the pros and cons of various technical 

approaches if they are deliberative in nature. 

 The project file should not contain contractual materials: 

 ERG’s contracts with EPA or our subcontractors; 

 Work assignments, work plans, monthly reports, etc.; 

 Contract performance evaluations; and 

 Any other material relating to the contract between ERG and EPA. 

 All items in the 304m project file will be assigned an ERG document control number 

(DCN) for document management purposes. Documents that become part of an EPA 

docket will be assigned an additional document number through the Federal Docket 

Management System (FDMS). See Section 2.2 for more information. 

1.3 Docket

 An official docket serves as the repository for the collection of documents or information 

related to a particular agency action or activity. The official docket generally consists of 

the documents specifically referenced in the Federal Register notices, any public 

comments received, and other information used by decision-makers, or otherwise related 

to the Agency action or activity. Agencies most commonly use dockets for regulatory 

actions, but dockets may also be used for various other non-rulemaking activities, such as 

Federal Register notices seeking public comments on draft guidance, policy statements, 

information collection requests under the Paperwork Reduction Act, and other non-rule 

activities. Each time an Agency action is announced in the Federal Register, a docket is 

established and assigned a tracking number to accumulate materials throughout the 

development process. 

 Multiple dockets will be created from the 304m project file. As project file documents are 

identified for inclusion in a specific docket, they will be assigned Docket Numbers. 

1.4 Federal Docket Management System (FDMS)

 FDMS is designed for use by over a hundred federal agencies and entities. FDMS is built 

on a document management system platform and has Internet access for both public users 

and agency personnel. FDMS is used to establish the public docket, index the docket 

contents, and to the extent feasible, provide the electronic version of publicly available 

docket materials. On November 28, 2005 FDMS replaced EDocket as EPA’s docketing 

system. The public interface with FDMS can be accessed at http://www.regulations.gov. 
1-4

1.5 Electronic Project File

 The electronic project file is the network area in which ERG stores the electronic version 

of items in the 304m project file. These files are named by DCN. Electronic versions of 

any CBI items in the 304m project file will be stored in 304(m) area on the CBI server. 

1.6 Contract File

 The contract file contains materials specific to ERG’s management of the contract with 

EPA. These materials would not be passed on to a succeeding contractor and would be 

retained by ERG at the conclusion of the contract. The contract file contains the 

following: 

 The contract; 

 Work assignments; 

 Work plans and cost estimates; 

 Contract and task instructions; 

 Weekly and monthly reports; 

 Invoices; 

 Contract performance evaluations; 

 Project wrap-up meeting notes and reports; 

 ERG document review sign-off sheets (completed for all project deliverables); 

and 

 Correspondence with the EPA Contracting Officer. 

Items in the ERG contract file are filed separately from the 304m project file and are not 

assigned DCNs. 

1.7 Personal Files

 Personal files include project team member notes that are not necessarily interpretable by 

others, as well as copies of non-CBI materials that are referred to frequently. Copies will 

be minimized to keep file space requirements under control. Working drafts of CBI and 

CBI computer files are managed according to ERG’s CBI Plan. 

1.8 Project File Index

 The project file index is a listing of all documents in the 304m project file. The index is a 

computerized database that allows for sorting and searching the project file by key word, 

section, date, DCN, docket number, etc. The project file index lists all documents, CBI 

and non-CBI. Index entries should not contain CBI information. The index includes a 

field that designates the CBI status of each item. See Section 2.3 for more details on the 

project file index. 

1.9 FDMS Metadata

 Metadata are descriptive information about the elements of a set of data. For FDMS the 

“elements” are documents and the “set of data” is the docket. Thus, FDMS metadata are 
1-5

information that describes each document in a docket. FDMS metadata are similar to the 

information contained in the project file index, and include among other information, the 

title, abstract, author, author date, source citation and page count.

1.10 Confidential Business Information (CBI)

 At the time a business or trade association supplies information to EPA, they may assert a 

business confidentiality claim covering all or part of the information. If no such claim 

accompanies the information, EPA may make it available to the public without further 

notice to the business. If EPA receives a request from an outside party for information 

claimed confidential, it will determine if the information is entitled to confidential 

treatment (see 40 CFR Part 2). Please refer to ERG’s Security Plan for Handling 

Confidential Business Information Under the Clean Water Act, dated March 2004, for 

further information on handling CBI. 

 As specified in ERG’s CBI Plan, documents containing CBI will be stored in a 

designated locked archive or file cabinet. Electronic files containing CBI will be stored 

on ERG’s separate, limited-access CBI server. 

 Documents containing CBI will be sanitized prior to their placement in the public docket. 

The original non-sanitized version of the document will be maintained as a CBI 

document. 

1.11 CBI-Deducible Information

 CBI-deducible information is information that is not CBI, but when used in conjunction 

with other publicly-available materials, can be used to deduce CBI. Examples of 

documents containing CBI-deducible information include pre-test questionnaires and 

non-CBI screener questionnaires which contain both facility identifier information (e.g., 

facility name, address, contacts, etc.) and facility codes. To prevent the deduction of CBI, 

documents containing CBI-deducible information will be sanitized prior to their 

placement in the public docket. The sanitization step will be designed to remove the 

information that allows CBI to be deduced. The original non-sanitized version of the 

document will be maintained as a CBI document. 
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2.0 GENERAL PROCEDURES

 All 304m project file items (i.e., excluding ERG contract file items) will be recorded in 

the project file index and assigned a unique DCN (discussed in section 2.2). Project file 

items are those items and materials which are defined in Section 1.2 of this project file 

plan. Team members will submit items that are ready to be entered into the project file, 

using the steps detailed further in this section, to the ERG staff member with primary 

responsibility for the project file index (the index keeper). The index keeper will issue 

DCNs as individual documents are generated and submitted to her. 

 The outline for the project file, which specifies project file sections, is included as 

Attachment 1 to this plan. The project file outline will be modified as needed during the 

performance of this work. Except for CBI documents, project file materials will be stored 

in the 304m electronic project file on ERG’s network. The electronic project file will 

include folders for each EPA docket that the 304m project file supports. The electronic 

project file will contain a separate folder (labeled “project file”) for materials that are not 

part of a docket. 

 As ERG is directed by EPA to assemble a docket supporting an Agency action, a subset 

of the items included in the 304m project file will be identified for inclusion in that 

docket. The appropriate docket number will be added to the project file index database to 

identify these items. Electronic files of these documents will be moved from the project 

file folder to the appropriate docket folder. 

 If any items identified for inclusion in the docket contain CBI or CBI-deducible 

information, a sanitized version of the item will be prepared. If CBI is removed from a 

document to create a “sanitized” version of the document, that document will receive a 

new DCN. The “sanitized” version of the document will be designated with a non-CBI 

cover sheet and noted “sanitized version.” In some cases it may be impossible to produce 

a sanitized version of the document. In these cases, the document will be described in the 

index and the CBI document will be stored on the CBI server. 

2.1 Submitting Material to the Project File

 This section presents the processes to be used to submit materials to the Project File, first 

as step-by-step procedures (Section 2.1.1) then in a more detailed discussion of the 

submission process (Section 2.1.2) 

2.1.1 Step-By-Step Process for Submitting Project File Materials 

 Documents will be submitted to the project file following the steps below: 

1. If the document is in a format that can easily be converted to a PDF (e.g., Word 

document, Web site, Visio diagram, email), convert the document to PDF. If the 

document is hard copy, either scan the document in as a pdf or request assistance from 

ERG docket staff for scanning support. 
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2. Complete an electronic project file log-in form (see Attachment 1) using the instructions 

below. 

• DCN: Leave this entry blank; the index keeper will assign this number. For 

logging in placeholder documents, put the DCN of the placeholder. For logging in 

attachments to a document, put MAIN in the DCN for the main document, and 

A1, A2, A3, etc. for the attachments to the document. 

 Placeholder (Y or N): If the document is not finalized and the metadata was 

entered to get a DCN for references, enter TRUE. If the document is finalized, 

enter FALSE. 

 Title: This should be the full title of the article, study, or report, limited to 400 

characters. For memoranda, letters, and e-mail correspondence, use the format: 

 Memorandum to Angela Beard, Vice President, Medical Research 

Department, Flonasd Corporation: Subject Subject; 

 Letter to Susan Clark, Citizen: Subject Subject; or 

 Email to John Wright, Contractor, Viztronix: Subject Subject. 

 For records of telephone conversations (only informal; formal telephone 

conversations (e.g., conference call notes) are written as memoranda), use the 

format: 

 Notes from telephone conversation between John Smith, ERG and Jane 

Doe, XYZ Corporation, August 6, 2001: Subject Subject. 

For permits, fact sheets, and permit applications, use the format: 

 NPDES Permit: CF Industries, Inc., Donaldsonville, Louisiana; 

 NPDES Permit Fact Sheet: CF Industries, Inc., Donaldsonville, Louisiana; 

or 

 NPDES Permit Application: CF Industries, Inc., Donaldsonville, 

Louisiana. 

For CBI documents, use the format: 

 CBI Document Title. 

 For Placeholder submittals, use the format: 

 PLACHOLDER: Document Title. 

 Abstract: This field is used to provide additional description of the individual 

document. It may be the continuation of a lengthy title. The subject of a 

memorandum, email, or letter should be entered as the abstract. Be descriptive; do 

not simply repeat information that is contained in the title. For permits, fact 
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sheets, and permit applications, the abstract should be the NPDES permit number. 

Abstracts are limited to 500 characters. 

 Document Sub-type: This is the type of document. Choose from the following 

types. 

 

Sub-Type Description 

Analysis A review and summation of data or facts which might be used in a report 

and/or study or which might serve as the basis of an audit, assessment, or 

evaluation. 

Comment Response Agency responses to public comments. 

Data Facts and figures used to support a position or for the modeling or 

forecasting of outcomes. Typically these records are provided electronically 

as data dumps on alternative media or as listings or spreadsheets. 

Economic Analysis A review and summation of economic data or facts. 

Fact/Data Sheet This subtype includes Material Safety Data Sheets (MSDS). Formalized 

information regarding a particular event, chemical, product, or other used as 

a tool to disseminate knowledge in a standardized factual manner. Broad 

announcements of events or information might otherwise be classified as 

"Press Releases, Public Announcements, Public Notices." 

Federal Register 

Document 

A draft or formal document published or to be published in the Federal 

Register which is used as a supporting document as opposed to authorizing a 

comment period or other action. 

Form Any government form not specific elsewhere or not part of a larger subtype 

category such as audit forms which should be classified under "Audit, 

Assessment, Evaluation." 

Guidance, 

Interpretation, Policy, 

Procedure 

Documents which provide direction to Agency employees, contractors, or the 

public including Standard Operating Procedures, methodologies, and 

guidelines. Documents which alert others to events used primarily to 

distribute broad knowledge in a standardized manner. 

ICR Supporting 

Statement 

The supporting statement which accompanies an ICR. 

Index A listing of materials or cross-reference of sources or citations in a 

publication, report or study. 

Interagency Review Draft materials reviewed by outside entities which show signs of being 

edited including redline/strikeouts. Do not include specific OMB reviews of 

documents in this category. See "Office of Management and Budget" below. 

Letter, Memorandum, 

Email 

Correspondence both internal and external to the Agency. 

Map A stand-alone map not included in the body of a report, study, presentation, 

etc. 

Meeting or 

Teleconference 

Materials 

Telephone contact reports, meeting minutes, and materials used to schedule, 

inform, conduct or summarize a meeting, teleconference, or less formal 

telephone call including but not limited to: agenda, 

presentations/handouts/slides, and attendee lists/sign-in sheets. 

Office of Management 

and Budget (OMB) 

Correspondence to and from and drafts reviewed by specifically by OMB. 

Other Non-copyright protected web pages. 

Permit, Registration A form which registers or permits the holder to perform a certain action or to 

use a specific chemical (e.g., NPDES discharge permit). 

Physical Item Any item which is considered a record under the NARA definition but which 

cannot be otherwise classified as a document or be imported as an image into 

the system such as a brick, paper plate, or bag. 

Press Release, Public 

Announcement/Notice 

Documents which alert others to events used primarily to distribute broad 

knowledge in a standardized manner. 
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Sub-Type Description 

Public Hearing 

Transcript, Deposition, 

Testimony 

Documents that reflect the words spoken during a legal or administrative law 

proceeding or interview, typically created by a court reporter. 

Publication; 

Copyrighted Material 

Any non-governmental work which appears to be afforded US copyright 

protection including journal or magazine articles, abstracts, books or any 

portion thereof, newspaper articles, online/trade articles, online news wires 

or services including MSN.com or CNN.com 

Publication; Other 

Governmental 

Federal/state/local government publication other than EPA publications. 

Publication; USEPA USEPA publication; include an EPA Publication Number in the title. 

Report A statement of fact and findings usually formalized. This subtype includes 

status reports on projects or contracts as well as outcomes and findings from 

the analysis, audit, review or study of processes or procedures whether 

scientific or business in function. 

Signed Federal Register 

Document 

Document authorizing the submission to and release of a Federal Register by 

NARA 

Speech Presentation or transcript of a speech 

Study A study is a compilation of analysis, data, multiple assessment or audits to 

ascertain the strength, accuracy or outcome of a position or methodology. 

Studies differ from reports in that a study offers more detailed scientific data, 

facts or figures from a variety of sources. 

Test Data 

• Author Name: Name of the individual who authored, edited, compiled or wrote 

the memorandum, report, study, article, or book. Author Name is limited to 25 

characters. For documents with multiple authors, use the format: Bartram, 

Deborah, et. al. 

• Author Affiliation: The affiliation of the author. For documents written by ERG 

staff, use the format: Eastern Research Group, Inc. For documents written by EPA 

staff, use the format: U.S. EPA. 

• Author Date: Enter as MM/DD/YYYY. Provide the date of publication, issue, 

edition, or version. Letters and memoranda usually bear a date in their respective 

headings. Reports, reviews, and studies usually have a date located within their 

respective forwards. Publications bear copyright dates. For meeting and telephone 

notes provide the date of the actual event. If only the month and year are known, 

enter the first day of the month. For example: use 05/01/2002 rather than 05/2002. 

• Page Count: Enter the total number of pages of the PDF. If the document was not 

converted to PDF (e.g., Excel file or Access database), leave the page count 

blank. Page Count is limited to five characters. 

• Category/Industry: If the document pertains to an existing ELG, provide the 

category name from the drop down menu. If the document pertains to an industry 

without existing ELGs, provide the industry name from the drop down menu. If 

the industry name is not in the drop down menu, type in the name. If the 

document is not industry-specific, leave this field blank (e.g., Technical Support 

Document). 
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• Copyright Protected (Y or N): If the document is copyrighted, enter TRUE, and 

make sure the document sub-type is “Publication; Copyrighted Material.” If the 

document is not copyrighted, enter FALSE. 

• Source Citation: For copyright protected material, enter the bibliographic 

citation, excluding the title, author name, and date because those are included in 

other fields. Source citations are limited to 150 characters. If the copyrighted 

document is a Web site, use the format: 

 Internet Materials: <WEBSITE>. (Accessed DATE). 

If the website is above format is longer than 150 characters, just put the website. 

If the copyrighted document is a journal article, use the format: 

 Journal Article: Nature 393(2002):639-40; or 

 Article in Electronic Journal: JAMA. 287, no. 5 (2001), http:/jama.amaassn.org/issues/v287n5/rfull/joc10108.html (accessed January 7, 2002). 

See the ERG Style Guide, Appendix C (available under tools on the ERG 

Intranet) for additional bibliographic formats. 

• Confidential Business Information (Y or N): If the document contains CBI or is 

CBI-deducible, enter TRUE, and make sure “CBI” is at the beginning of the title. 

If the entire document is non-confidential or has been sanitized, enter FALSE. 

• NPDES Permit ID Number: If the information in the document is specific to a 

single facility, enter the facility’s NPDES permit ID. This is typically for notes 

from a telephone conversations, permits, permit fact sheets, permit applications, 

or facility websites. If the facility’s NPDES permit ID is not readily available, 

leave this field blank. 

• TRI ID Number: If the information in the document is specific to a single 

facility, enter the facility’s TRI ID. This is typically for notes from a telephone 

conversation, sampling data, or facility websites. If the facility’s TRI ID is not 

readily available, leave this field blank. 

• Keyword 1 and Keyword 2: Enter keywords about the document that could be 

used to search the index for specific documents. Do not repeat information in 

other index fields (e.g., title, abstract, NPDES permit ID, or TRI ID). 

• Electronic Copy File Location: Copy the full file path, including document title, 

into this field. For example: Q:\304m\2008 Annual Review and Final Plan\Final 

Reports - Formatted\2008 TSD\ 2008 TSD.2008.09.04 - Draft Final Version 

formatted 508.pdf. Identify if the item is stored on the CBI network by putting 

“CBI” in front of the file path. 

• Docket Item (Y or N): If the document is for the docket, enter TRUE; if the 

document is for the project file only, enter FALSE. 
2-6

• Project File Section Number: Enter the project file section number for the 

subject outline of the 304m project file (see Attachment 1). 

• Submitter Name: Enter your name. If a project assistant is entering the 

information for you, have them enter your name. 

3. Submit the log-in form and documents to the index keeper. If you have: 

• A non-CBI electronic file, email the file and the log-in form to 

304m_record@erg.com. Be sure to include the filename and path to the 

network area on the log-in form. 

• A CBI electronic file, email only the log-in form to 304m_record@erg.com. Be 

sure to include the filename and path to the CBI network area on the log-in 

form. 

• A hard copy item that cannot be scanned (such as a large map or a physical 

specimen): 

 Email the log-in form to 304m_record@erg.com and indicate in the 

message that the document is not electronic; and 

 Print out the log-in form, attach it to the item, and put the item with the 

log-in form in the 304m project file inbox (in Teresa’s office). 

• A database or other file that must be saved to cd instead of being uploaded: 

 Email the log-in form to 304m_record@erg.com and indicate in the 

message that the document will be provided on CD or DVD; and 

 Print out the log-in form, make two copies of the CD or DVD, attach the 

log-in form to the disks, and place them in the 304m project file inbox (in 

Teresa’s office). 

Adding the Document to the Record and Electronic Project File

 The index keeper, or designee, will check the 304m_record@erg.com email box weekly 

to determine if documents have been submitted for login. The index keeper will add the 

documents to the record index on a bi-weekly basis during slow periods (less than 10 

items per week) and weekly during high paced periods (more than 10 items per week). 

4. The index keeper will import the log-in file into the record index and append it to the 

304m Index table using the steps outlined in Attachment 2. The index keeper will also 

update the following fields when the log-in file is appended to the 304m Index table: 

• EPA Docket 2010: This field indicates that the document was identified as 

Docket Item ‘Y’ and will be placed in the docket for the 2010 ELG Plan. Enter 

“EPA-HQ-OW-2008-0517.” Documents that are identified as Docket Item ‘N’ 

will have blank fields in this column. 

• Input Date: The date the index keeper added the item to the index. 
2-7

• Metadata Checked (Y or N): This field indicates if the metadata has been 

checked. All documents added to the 304m Index will have ‘N’ in this column. 

• File Checked (Y or N): This field indicates if the file in the electronic project file 

areas has been checked. All documents added to the 304m Index will have ‘N’ in 

this column.

• Metadata Approved (Y or N): This field indicates if the metadata has been 

approved for upload to FDMS. All documents added to the 304m Index will have 

‘N’ in this column. 

5. The index keeper will compare the imported table to the updated 304m Index to make 

sure the information was added correctly. 

6. The index keeper will save the documents to the designated electronic project file areas. 

• If the item is not CBI and: 

 Not copyright protected, the index keeper will save the document as 

dcn.pdf to: non-CBI network Q:\304m\Record\Electronic Project File 

(with appropriate subfolder). 

 Copyright protected, the index keeper will save the document as dcn.pdf 

to: non-CBI network Q:\304m\Record\Electronic Project File. 

 Hardcopy, the index keeper will scan the document and save it to the 

respective electronic project file area. 

• If the item is CBI, the index keeper will use the Electronic Copy File Location to 

save the document to the proper project-related area on the CBI network 

(either p:CBI\304m, p:CBI\steam\, or other). 

7. The index keeper will email the submitter the DCNs to the documents they submitted 

when they are added to the 304m Index. 
2-8

QA Process for Metadata, Document, and Upload to FDMS

The index keeper will generate quarterly reports and provide them to the appropriate project file 

section leads to review the metadata. The reports will include at least the following fields 

from 304m Index: 

• DCN; 

• Placeholder; 

• Title; 

• Abstract; 

• Document Sub-Type; 

• Author; 

• Category Industry; 

• Copyright Protected; 

• CBI; 

• Docket Item; 

• Project File Section Number; 

• Metadata Checked; 

• File Checked; and 

• Metadata Approved. 

1. The project file section leads will review the metadata and identify any changes for the index 

keeper to make. The project file section lead will change the Metadata Checked field from 

‘N’ to ‘Y’ for metadata that do not need changed. 

2. The index keeper will update the metadata based on the project file section leads’ 

comments. The index keeper will update the Metadata Checked field for the metadata 

that does not need changing to ‘Y.’ 

3. For a selected quarterly report, repeat steps 1 through 3 until all the Metadata Checked 

fields are changed to ‘Y.’ 

4. The index keeper will perform quarterly audits of the documents identified as Placeholder 

‘N’ in the electronic project file areas and compare the files to the metadata. 

18.1. For documents that match the metadata, the index keeper will update the File 

Checked field from ‘N’ to ‘Y;’ 

18.2. For documents that do not match the metadata or are missing but not identified as 

Placeholder ‘N:’ 

18.2.1. The index keeper will email the project file section lead the DCN and 

document title. 

18.2.2. The project file section lead will locate the document and email either the 

electronic copy file location or document to the index keeper. 

18.2.3. The index keeper will update the electronic project file area with the 

correct document and update the File Checked field from ‘N’ to ‘Y.’ 

 Additional explanation of the submission process is provided below. 
2-9

2.1.2 Detailed Discussion of Document Submission Process 

 Because the official dockets supporting EPA actions consist, with a few exceptions, of 

electronic files, you should submit materials to the project file in electronic format as 

much as possible. In addition to final reports supporting the EPA action, project file 

materials include ERG deliverables and background materials such as telephone contact 

reports, journal articles, NPDES permits, etc. These materials should be submitted to the 

project file as they are finalized even if EPA has not determined if they will be part of an 

official docket. 

 As of November 28, 2005 EPA is using the Federal Docket Management System 

(FDMS) to store and manage its dockets. FDMS is a web-based database that holds 

document records (metadata) that describe each document in a docket and electronic 

copies of the documents. To expedite development and delivery of the docket, the 304m 

project file will be stored in the 304m electronic project file. Because the FDMSpreferred format for documents is portable data format (pdf), ERG will store project file 

documents as pdf files in the electronic project file network area. The electronic project 

file will have read-only access to preserve the integrity of the project file items. In 

addition to standard network backups, the index keeper will back up additions to 

electronic project file on CD or DVD on a regular basis. The DCN will serve as the 

filename. For example, 00066.pdf will be the electronic version of document 00066. If a 

DCN is comprised of multiple documents, a folder will be created using the DCN as the 

folder name, and each document will be available within the folder. The individual files 

will not be renamed. 

 The first step in submitting materials to the project file is to complete an electronic 

project file log-in form and e-mail it to the index keeper with the item to be added to the 

project file. The index keeper will add the data from the log-in form to the project file 

index and assign the item a DCN. The project file index is used to complete the FDMS 

metadata description for the document, so it is essential that the log-in form is completed 

properly. The index keeper will store project file documents in the electronic project file 

(electronic form), with a few exceptions described later. 

 Project deliverables, with deliverable review sign off sheets. If the item submitted to the 

project file is a project deliverable, print out the project file log-in form and attach 

printouts of the transmittal e-mail or transmittal letter and the deliverable review sign-off 

sheets. After the index keeper assigns a DCN to the document, she will record the DCN 

on the cover letter and review sheet and file them in the contract file. 

 Related materials. Related materials that do not need to be indexed separately can be 

logged in as one item and given one DCN. Examples of materials that may be included 

under one DCN are: 

 Materials presented by several participants in one meeting; 

 A series of telecons between two people about one subject; 

 Correspondence between two people on one subject; and 

 A related series of calculation sheets. 
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 CBI Items. Team members submitting CBI items for the electronic project file must 

include on the log-in form the full CBI Server path and filename for the electronic 

version of the item that is to be added to the CBI Server electronic project file. That 

electronic version will then be added to the CBI Server electronic project file area and 

renamed using the DCN. 

 Electronic Files on compact disk (CD), digital video disk (DVD), or diskette. As noted 

above, pdf is the FDMS preferred file format. Some docket items, such as databases and 

large spreadsheets cannot be saved as pdf files. These items will be submitted to the EPA 

docket on DVD, CD, or diskette. Copies will be stored in the ERG National Strategy 

archive, similar to hard copy printouts of documents. Similarly, computer files received 

on diskettes, CDs, or DVDs will be identified in the project file index in the title field as 

being on diskette, CD or DVD. Diskettes, CDs, or DVDs will be clearly marked with the 

item name and DCN and filed in the ERG National Strategy archive in 

pouches/envelopes attached to the project file item file folder. 

 Internet Website Material. Because web addresses and web site content may change over 

time and become unavailable electronically, Internet website materials should be saved as 

a pdf file (or html file if the team member’s computer is not equipped with Adobe 

Writer®) and printed out. Log-in information should include the URL and date accessed. 

The index keeper will convert any html files to pdf and add the electronic version to the 

electronic project file. 

 E-mail Correspondence. E-mail correspondence to be added to the project file should be 

saved as a pdf file and managed like other project file documents. DO NOT simply 

forward the message on to the index keeper. 

 Copyright Protected Material. Copyright protected material is often part of an official 

docket. However, these materials cannot be stored in FDMS. FDMS will include the 

metadata for the copyright protected material, but will not include an electronic copy of 

the document. ERG will provide electronic copies of copyright protected material to the 

docket office via cd or email. The docket staff will produce hard copies of copyright 

protected materials that will be available in the docket office for public review. For 

ERG’s project files, copyright protected material will be saved in a separate section of the 

electronic project file area of the network 

 Hard-Copy Items. Items that are only available in hard copy format must be converted to 

an electronic file, typically by scanning and saving the material in pdf format. The team 

member will provide the hard copy and completed log-in form to the index keeper, who 

will arrange for creation of the electronic version. Exceptions include copyright protected 

material (e.g., books and other published material) and physical objects (maps, aerial 

photos, colored charts, etc.). 

 NPDES Permits. For NPDES permits and permit fact sheets, ERG will use the following 

conventions: 

 Title is “NPDES Permit: Name of Plant” or “Draft NPDES Permit: Name 

 of Plant”; and 

 Abstract is the NPDES permit number (e.g., PAXXXXXXX). 
2-11

 NPDES Permit Fact Sheets. For NPDES permits and permit fact sheets, ERG will use the 

following conventions: 

 Title is “NPDES Permit Fact Sheet: Name of Plant”; and 

 Abstract is the NPDES permit number (e.g., PAXXXXXXX). 

2.2 Document Control Numbers (DCNs)

 All 304m project file items will be assigned a unique document control number (DCN). 

The ERG staff member with primary responsibility for the project file index (the index 

keeper) will issue DCNs as individual documents are generated and submitted. The index 

keeper may also issue batches of DCNs to the EPA WAM to assign to materials received 

or generated at EAD. Each DCN will consist of five digits plus extensions. 

2.2.1 Appendices and Attachments 

 Major appendices and attachments to documents, such as the analytical data reports 

attached to Sampling Episode Reports, will be given the same DCN as the parent 

document with an extension added to designate the appendix. For example, 09289A001 

will designate Appendix 1 to document 09289. 

2.2.2 Copies 

 In accordance with ERG’s CBI plan, each individual copy of a CBI document will be 

tracked in a separate electronic copy log (the CBI copy log). The copy log tracks the copy 

numbers, date generated, destination, and ultimate disposition (e.g., returned to ERG, 

destroyed). The copy number of a CBI document will be incorporated into the DCN as an 

extension. For example, 09287C1 will designate copy 1 of document 09287. Multiple 

copies of non-CBI materials will not be tracked or designated. 

2.2.3 CBI Documents 

 CBI documents will be designated in the project file index as a “yes” in the CBI column 

of the index. A sanitized version of a CBI document will receive a unique DCN. CBI 

documents will be stored in a designated, locked storage space. CBI electronic files will 

be stored on the CBI server. Names of all files containing CBI will begin with CBI (e.g., 

CBI0661.pdf). 

2.3 Project File Index

 The project file index will list all project file items. The index will be maintained using 

Access® 2003 database software. Entries to the index will be made by the index keeper, 

or her designee. 304m project team members will have read-only access to the index via 

the network. The file will be located under Q:\304m\Record\. 

2.3.1 Index Structure 

 The index key fields are listed below with a brief description of their content. The first 16 

fields are included on the project file log-in form and will be completed by the document 
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submitter. These entries are used to complete the FDMS metadata description of the 

document, so it is essential that the log-in form entries are consistent with FDMS 

metadata requirements. Additional index fields are completed by the index keeper as 

described below. An asterix (*) preceding the index field name indicates that it is 

included in the FDMS system.2

 Four of the index fields that will be included in FDMS (Document Title, Abstract, Source 

Citation, Author Name) are free text format. However, information should be recorded in 

a consistent format to ensure easy retrieval. Because the Document Title is a searchable 

field, it is especially important that it be free of typos and use consistent abbreviations, 

punctuation, and capitalization. FDMS guidelines for free text fields are presented in 

Attachment 3. 

 FDMS free text fields are size limited, in terms of number of characters (including blank 

spaces). The character count of an index entry can be checked using tools/word count in 

MS Word. 

 *Title: This should be the full title of the article, study, or report, limited to 400 

characters. For memoranda, letters, and e-mail correspondence, use the format: 

 Memorandum to Angela Beard, Vice President, Medical Research 

Department, Flonase Corporation Re: [Insert Subject Line of 

Memorandum], 

 Letter to Susan Clark, Citizen, or 

 Email to John Wright, Contractor, Viztronix. 

 For records of telephone conversations, use the format: 

 Notes from telephone conversation between John Smith, ERG and Jane 

 Doe, XYZ Corporation, August 6, 2001. 

 When entering the document title into the FDMS metadata field, the ERG index keeper 

or her designee will add our DCN to the end of the title. 

 *Abstract: This field is used to provide additional description of the individual 

document. It may be the continuation of a lengthy title.3 The subject of a 

memorandum, email, or letter should be entered as the abstract. Be descriptive; do 

not simply repeat information that is contained in the title. Abstracts are limited to 

500 characters. 

 

2

 Only two fields are required to upload a document into FDMS: the document title and document type. However, 

ERG will include information from all fields listed in this document as part of its record-keeping support to EPA. 

3

 Docket staff also use the abstract to explain aspects of the document that might otherwise be confusing to the user 

(for example, if a document file is not included because it is CBI or a duplicate of another document). 
2-13

 *Document Sub-type: This is an FDMS field with a drop-down menu of 

allowable document subtypes. To expedite the index keeper’s entry of FDMS 

metadata, choose from the following types. 

 
2-14

Sub-Type Description 

Analysis A review and summation of data or facts which might be used in a report 

and/or study or which might serve as the basis of an audit, assessment, or 

evaluation. 

Comment Response Agency responses to public comments. 

Data Facts and figures used to support a position or for the modeling or 

forecasting of outcomes. Typically these records are provided 

electronically as data dumps on alternative media or as listings or 

spreadsheets. 

Economic Analysis A review and summation of economic data or facts. 

Fact/Data Sheet This subtype includes Material Safety Data Sheets (MSDS). Formalized 

information regarding a particular event, chemical, product, or other used 

as a tool to disseminate knowledge in a standardized factual manner. 

Broad announcements of events or information might otherwise be 

classified as "Press Releases, Public Announcements, Public Notices." 

Federal Register 

Document 

A draft or formal document published or to be published in the Federal 

Register which is used as a supporting document as opposed to 

authorizing a comment period or other action. 

Form Any government form not specific elsewhere or not part of a larger 

subtype category such as audit forms which should be classified under 

"Audit, Assessment, Evaluation." 

Guidance, 

Interpretation, Policy, 

Procedure 

Documents which provide direction to Agency employees, contractors, 

or the public including Standard Operating Procedures, methodologies, 

and guidelines. Documents which alert others to events used primarily to 

distribute broad knowledge in a standardized manner. 

ICR Supporting 

Statement 

The supporting statement which accompanies an ICR. 

Index A listing of materials or cross-reference of sources or citations in a 

publication, report or study. 

Interagency Review Draft materials reviewed by outside entities which show signs of being 

edited including redline/strikeouts. Do not include specific OMB reviews 

of documents in this category. See "Office of Management and Budget" 

below. 

Letter, Memorandum, 

Email 

Correspondence both internal and external to the Agency. 

Map A stand-alone map not included in the body of a report, study, 

presentation, etc. 

Meeting or 

Teleconference 

Materials 

Telephone contact reports, meeting minutes, and materials used to 

schedule, inform, conduct or summarize a meeting, teleconference, or 

less formal telephone call including but not limited to: agenda, 

presentations/handouts/slides, and attendee lists/sign-in sheets. 

Office of Management 

and Budget (OMB) 

Correspondence to and from and drafts reviewed by specifically by 

OMB. 

Other Non-copyright protected web pages. 

Permit, Registration A form which registers or permits the holder to perform a certain action 

or to use a specific chemical (e.g., NPDES discharge permit). 

Physical Item Any item which is considered a record under the NARA definition but 

which cannot be otherwise classified as a document or be imported as an 

image into the system such as a brick, paper plate, or bag. 

Press Release, Public 

Announcement/Notice 

Documents which alert others to events used primarily to distribute 

broad knowledge in a standardized manner. 

Public Hearing 

Transcript, 

Deposition, 

Testimony 

Documents that reflect the words spoken during a legal or administrative 

law proceeding or interview, typically created by a court reporter. 
2-15

Sub-Type Description 

Publication; 

Copyrighted Material 

Any non-governmental work which appears to be afforded US copyright 

protection including journal or magazine articles, abstracts, books or any 

portion thereof, newspaper articles, online/trade articles, online news 

wires or services including MSN.com or CNN.com 

Publication; Other 

Governmental 

Federal/state/local government publication other than EPA publications. 

Publication; USEPA USEPA publication; include an EPA Publication Number in the title. 

Report A statement of fact and findings usually formalized. This subtype 

includes status reports on projects or contracts as well as outcomes and 

findings from the analysis, audit, review or study of processes or 

procedures whether scientific or business in function. 

Signed Federal 

Register Document 

Document authorizing the submission to and release of a Federal 

Register by NARA 

Speech Presentation or transcript of a speech 

Study A study is a compilation of analysis, data, multiple assessment or audits 

to ascertain the strength, accuracy or outcome of a position or 

methodology. Studies differ from reports in that a study offers more 

detailed scientific data, facts or figures from a variety of sources. 

Test Data 

• *Source Citation: For copyright protected material, this is a mandatory field. It 

consists of a bibliographic citation the public can use to identify the document and 

to locate a copy through alternative means such as a reference library. Source 

citation is an important part of the metadata for copyright protected documents 

because it allows FDMS to link back to the paper record. 

The source citation does NOT need to include the title or the author name because 

those metadata are captured elsewhere in the system. The citation should, 

however, include such standard information as the publisher’s name and city, date 

of publication, editor or compilers’ names, and volume or serial numbers. Source 

citations are limited to 150 characters. 

 See the ERG Style Guide, Appendix C (available under tools on the ERG 

Intranet) for bibliographic formats. Three commonly used citations are shown 

below: 

 Journal article: Nature 393(2002):639-40. 

 Article in electronic journal: Journal of the American Medical Association. 287, 

no. 5 (2001), http:/jama.ama-assn.org/issues/v287n5/rfull/joc10108.html 

(accessed January 7, 2002). 

 Internet Materials: <www.epa.gov/water/residuals/wtrdoc.html>. (Accessed May 

17, 1998). 

• *Author Name: name of the individual who authored, edited, compiled or wrote 

the memorandum, report, study, article, or book. For documents with multiple 

authors, list the primary author (e.g., Bartram, Deborah, et. al.). Use full names 

whenever possible. Author Name is limited to 25 characters. 
2-16

• Author Affiliation: The affiliation of the author. For documents written by ERG 

staff, use the format: Eastern Research Group, Inc. For documents written by 

EPA, use the format: U.S. EPA. 

• *Author Date: Enter as MM/DD/YYYY. Provide the date of publication, issue, 

edition, or version. Letters and memoranda usually bear a date in their respective 

headings. Reports, reviews, and studies usually have a date located within their 

respective forwards. Publications bear copyright dates. For meeting and telephone 

notes provide the date of the actual event. If only the month and year are known, 

enter the first day of the month. For example: use 05/01/2002 rather than 05/2002. 

• Page Count: Enter the total number of pages of the PDF. If the document is 

copyrighted, include the page count of the paper document. This is the total page 

count so be sure to include all blank pages. Page Count is limited to 5 characters. 

• Category/Industry: This entry is specific to the 304m project file index and will 

not be included in the FDMS metadata. If the document pertains to an existing 

ELG category, provide an abbreviated category name (e.g., OCPSF, pulp and 

paper). If the document pertains to an industry without existing ELGs, provide the 

industry name (e.g., tobacco, PBST). If the document is not industry-specific, 

leave this field blank. 

• *Copyright Protected (Y or N): All project file items will be identified in the 

project file index as Y (the item is copyright protected) or N (the item is not 

copyright protected). The document sub-type of copyright protected material is 

typically “Publication; Copyrighted Material.” 

• Confidential Business Information (Y or N): All project file items will be 

identified in the project file index as Y (all or part of the item contains CBI or is 

CBI-deducible) or N (the entire item is non-confidential). 

• NPDES Permit ID Number: This entry is specific to the 304m project file index 

and will not be included in the FDMS metadata. Always include the NPDES 

permit ID number for permits. For information specific to a single facility (e.g., 

correspondence; telephone contact report) include the NPDES permit ID number 

as it is available. 

• TRI ID Number: This entry is specific to the 304m project file index and will 

not be included in the FDMS metadata. For information specific to a single 

facility (e.g., correspondence; telephone contact report) include the TRI ID 

number as it is available. 

• Keyword 1 and Keyword 2: This entry is specific to the 304m project file index; 

however, the key words will be included in FDMS metadata in the abstract field. 

Key words are intended to aid in searching the index for specific documents. Do 

not repeat information in other index entries. When completing the key word 

entry line on the log-in form, refer to the key words in the existing index database 

ensure correct and consistent spelling, abbreviation, and punctuation are used. 
2-17

• Electronic Copy File Location: This entry is specific to the 304m project file 

index and will not be included in the FDMS metadata. This field refers to the 

source location of the document on ERG’s network area. Once the document is 

submitted to the index keeper for addition to the project file, it will be re-saved 

with the DCN as the file name and stored in the electronic project file. Items 

stored on the CBI server should be identified as such. They will be stored in the 

electronic project file on the CBI server. 

• Docket Item (Y or N): Project file items will be identified in the project file 

index as Y (the item is or will be delivered to the EPA docket) or N (the item is 

project file, only, and will not be delivered to the EPA docket). The document 

submitter should complete this field, entering N if they are not certain that the 

document will be added to a docket. However, the list of items for the docket will 

be reviewed and approved by EPA before any documents are uploaded to FDMS. 

• Project File Section Number: To help locate documents addressing related 

topics or subjects ERG created a subject outline of the 304m project file (see 

Attachment 1). Each outline section is numbered. The individual submitting an 

item to the index keeper for inclusion in the project file will identify the outline 

section for the item. 

The index keeper adds the following information to the index as they manage the 

project file. 

• Document Control Number (DCN): This entry is specific to the 304m project 

file index; however, our DCN will be included in FDMS metadata at the end of 

the document title. FDMS will assign a separate, unique document ID to every 

document added to a docket. The index keeper will use the following convention 

for assigning DCNs: 

 DCN XXXX; 

 Attachments to the DCN will be DCN XXXXA001, DCN XXXXA002, 

etc. 

• Input Date: This field is the date the index keeper adds the item to the index, 

EDF, and/or Project File archive. 

• *EPA Docket Number: This field identifies the docket in which each document 

was originally placed: 

 EPA-HQ-OW-2003-0074 supports the 2004 ELG Plan; 

 EPA-HQ-OW-2004-0032 supports the 2006 ELG Plan; and 

 EPA-HQ-OW-2006-0771 supports the 2008 ELG Plan. 

 EPA will assign additional dockets to support subsequent biennial plans. 

• *Date to Docket: This field lists the date the item was delivered to the EPA 

docket or uploaded to FDMS. 
2-18

• Placeholder: A field used by the index keeper to track the flow of pre-assigned 

DCNs for documents that have not been finalize to upload into FDMS. 

• ERG_Project: This field is no longer actively used. It identifies items supporting 

the Petroleum Bulk Stations and Terminals detailed study conducted in 2003-

2004. 

• Source: This field is no longer actively used. It includes information about the 

source of the item in pre-FDMS format. 

• Recipient: This field is no longer actively used. It includes information about the 

recipient of correspondence. For FDMS, this information is included in the 

document title. 

• Placeholder: This field indicates if the DCN is being assigned as a placeholder 

until a document has been created. For example, report titles and dates may not be 

complete at the time their DCN is needed for reference. In this case, the index 

keeper assigns a placeholder DCN. Once the document is complete, the index 

keeper completes the metadata for the document and updates the Placeholder 

field. 
3-1

3.0 QUALITY CONTROL PROCEDURES

 Only fully legible, complete documents should be added to the project file, unless 

specifically noted as a document excerpt. All documents prepared by ERG will be 

reviewed prior to submission to the project file. This review will be documented on a 

Deliverable Review Sign-off Sheet. As indicated on the sign-off sheet, review of all 

deliverables includes checking and reviewing for completeness of supporting 

documentation. Data and calculations will be checked according to the appropriate ERG 

Standard Operating Procedure. The documentation (such as backup calculations, 

spreadsheets, and telephone contact reports) will be added to the project file at the same 

time as the document. In most cases, a document will be added to the 304m project file 

when it is delivered to EPA. 

 No item will be added to the project file index unless it is available in hard copy to be 

filed in the archive and/or electronic form for the electronic project file. No changes will 

be made to section assignments in the index unless the project file item is physically 

refiled. Correct spelling, standard key words, accepted abbreviations, and consistent 

format are required to ensure the index can function as a database. 

3.1 Responsibilities

 The overall responsibility for the quality of the project file and index belongs to the ERG 

Work Assignment 6-05 Work Assignment Manager (WAM). The index-keeper is 

responsible for the quality of the index (i.e., correct spelling, consistent format) and for 

correct filing of project file materials. Each team member is responsible for submitting 

materials to the project file in a timely fashion and is responsible for completing project 

file log-in forms when submitting materials. 

 The 304m technical team member providing the technical lead for a particular activity 

will be responsible for project file submittals on the activity, including index entries. 

They will also be responsible for ensuring that this plan is carried out and that materials 

are submitted to the project file in a timely manner. 

 Periodically, the ERG WAM will divide the project file into parts and assign each part to 

a 304m technical team member for review. In general, the team member providing the 

technical lead for the activity included in a project file section will be assigned that 

section for review. 

3.2 Project File Quality Review Procedures

 ERG will perform quality assurance/quality control checks on the project file index, hard 

copy project file, and the electronic project file on a periodic basis to ensure 

completeness and accuracy. ERG will also periodically review this plan for possible 

revision. 
3-2

3.2.1 Project File Index 

 After the index keeper or their designee completes a batch of new index entries 

(approximately 50 entries or fewer), they will print a list of the new entries. The list will 

be reviewed for spelling and format consistency. Approximately once a quarter, the index 

keeper will run database queries on the index to check for the following: 

• Errors in the metadata, such as missing fields, duplicate DCNs, duplicate entries, 

typos, etc. 

• Copyright protected material or other restricted use material that is not marked as 

such. For example, some site visit reports contain materials provided by the 

facility that was visited. The map or other document provided may contain a 

copyright symbol or a statement that the document’s use is restricted. In these 

cases, ERG project team members or EPA staff should obtain permission to make 

the document public or exclude the protected information from the document 

being uploaded. As another example, web sites are often copyright protecteded, 

but the registry symbol appears only on the home page. This type of document 

should also be marked as copyright protected. 

• Non-CBI material that contains the word “confidential” in the document. For 

example, facilities may provide a document to EPA that is not claimed as CBI; 

however, pages within the document have been marked with the words “For 

Internal Use Only” or “Confidential – Draft.” In these cases, ERG project team 

members or EPA staff should obtain permission to make the document public or 

exclude information marked “Confidential” from the document being uploaded. 

This check is important because if a document is uploaded to FDMS containing 

any indication of confidential or internal material, the FDMS docket staff will 

automatically designate it as CBI. 

3.2.2 Project File and Filing Review 

 Review of the project file content and filing will occur semi-annually. The index keeper 

will conduct the following checks: 

• Prepare a printout of the 304m project file index that supports the current docket; 

• Ensure all items listed in the index are filed in the archive in the section listed in 

the index; 

• Ensure all filed materials in the archive and electronic project file are listed in the 

index with complete and accurate information; 

• Ensure all deliverable items listed in the monthly reports are indexed and filed in 

the archive and electronic project file; and 

• Communicate all discrepancies to the ERG WAM for resolution. 
3-3

The ERG WAM will divide the index into parts and assign each part to a 304m technical 

team member. The technical team reviewers will conduct the following checks: 

• Resolve discrepancies identified by the index keeper; 

• Ensure all appropriate documents (e.g., deliverables, reference materials, etc.) 

have been entered into the project file; 

• Ensure all back-up materials (i.e., references, calculations, etc.) for each 

document are indexed and filed; 

• Ensure index entries accurately represent the material; and 

• Ensure the CBI and copyright status identification in the index and on the 

document is accurate and consistent. 

 When the project file reviews are complete, the team will meet to discuss and resolve 

discrepancies and to discuss any possible changes needed in the project file plan. 

3.2.3 Project File Plan Revision 

 This plan will be reviewed each year after the index-keeper and technical team have 

completed their annual reviews. As necessary, the ERG WAM will ensure the plan will 

be revised and submitted to EPA for review. All revisions to the plan will be 

communicated to the ERG team, following approval from EPA. 
4-1

4.0 DOCKET ASSEMBLY

 The 304m project file supports EPA’s biennial Effluent Guidelines plans. EPA 

opens a new docket for each plan. The docket numbers are listed in Table 4-1. 

Table 4-1. Effluent Guidelines Plans Docket Numbers 

Docket Number ELG Plan Year 

EPA-HQ-OW-2003-0074 2004 

EPA-HQ-OW-2004-0032 2006 

EPA-HQ-OW-2006-0771 2008 

EPA-HQ-OW-2008-0517 2010 

 EPA opens a docket prior to the publication of a preliminary plan. Next, the 

Federal Register (FR) notice of the preliminary plan and supporting documents are added to the 

docket. Public comments on the preliminary plan are added next. Finally, documents supporting 

the final plan, including responses to comments, and the Federal Register notice of the final plan 

are added to complete the docket. 

 EPA staff is responsible for opening the docket and working with the EPA Docket 

staff to create the docket in FDMS. The ERG index keeper (and a few other ERG project team 

members) has an FDMS user ID and password. EPA/EAD staff (the “docket contact” in FDMS) 

must grant permission, by FDMS user ID, for ERG staff to access a specific docket. Once access 

is granted, ERG staff can create documents by entering metadata and uploading document files. 

The FDMS web page can be accessed at http://www.fdms.gov; however, only approved users 

can upload files and access other FDMS tools. ERG’s Work Assignment Manager and Document 

Control Officer have access to FDMS. 

 EPA Docket staff conducts a series of QC steps on the created documents, 

eventually identifying the document as “Pending Post.” The document will not be released to the 

publicly accessible side of FDMS until a date (“docket phase posting date”) specified by the 

EPA/EAD docket contact. 

 ERG can create document records (enter metadata) without uploading the 

document files. Once a document file is uploaded, ERG cannot delete it. If the document has not 

been posted (released to the public), ERG can request the docket staff to delete the entire record 

(Document ID, metadata, and document) by moving it to an FDMS area called the “sandbox”. If 

the document has been posted, the docket cannot change or delete a posted entry, but will add the 

revised file and insert a comment to the original entry that a revised document has been uploaded 

with the new assigned FDMS number. Because of these limitations, it is essential that only final 

documents (no drafts!) be uploaded to FDMS. However, the document record can be created, 

and a Document ID assigned, without uploading the document file. Note, ERG can edit 

document records before public posting. 

 ERG will identify items from the project file to be included in the docket and 

designate those items in the record index, as discussed in Section 2.3.1. These items will include 

references cited in the Federal Register notice and other supporting documentation. Periodically 

during the development of each ELG plan, a printout of the index of the suggested docket 

materials will be submitted to EPA for review. Upon approval from EPA, ERG will add 

documents to the docket using FDMS by completing the document metadata and uploading the 
4-2

pdf files from ERG’s electronic project file. For electronic databases and large spreadsheets that 

can’t be rendered to pdf, ERG will complete the document metadata and obtain an FDMS 

“Document ID” for the document. ERG will provide electronic copies of these materials on 

removable media labeled with the Document ID number. 

 All documents will be added to the docket as pdf files, with the following exceptions: 

• Copyright protected material. ERG will provide electronic copies on removable 

media of these materials. 

• Physical objects (maps, aerial photos, colored charts, etc.). 

• Large documents that present an undue burden for ERG (as contractor to the EPA 

program office) to scan (determined after consultation with EPA/EAD and docket 

staff). 

• Databases and large spreadsheets that cannot be rendered to pdf. ERG will 

provide copies of these documents on DVD, CD, diskette, or other electronic 

medium acceptable to the docket. 

• Any document containing CBI. ERG will complete the FDMS metadata for CBI 

documents and include the following in the abstract field: “This document 

contains Confidential Business Information. Please contact the Document Control 

Officer listed in the Federal Register Notice if access is necessary.” ERG will not 

provide copies of CBI to the docket. 

 Below are abbreviated instructions for submitting material to the Docket. The index 

keeper and other staff will receive more detailed instructions prior to the use of FDMS. 

• FDMS Metadata Entry into the project file index, including adding the ERG DCN 

at the end of the FDMS document title. 

• EPA approves index entries from Access database printout. 

• Index keeper retypes (or block/copies) index information as FDMS metadata into 

the interface at http://www.fdms.gov, and each document is assigned an FDMS 

Document ID. Use the FDMS “create document” wizard for this process. 

• Add descriptions to the abstract of documents that will not be uploaded to FDMS: 

 CBI documents, 

 Copyright protected publications, 

 Databases and large spreadsheets, and 

 Other materials as directed by docket staff. 

• Assign a second staff person to open the metadata for a subset of the entries and 

compare the document details to the Access database printout. Any discrepancies 

will be brought to the attention of the index keeper, who will correct the FDMS 
4-3

metadata, as appropriate. The ERG work assignment manager and index keeper 

will determine the number of entries to review. 

• When a DCN is assigned, the pdf file is saved to the q:\304m\Record\Electronic 

Project File\ area. Assign a second staff person to open the pdf files for all entries 

and compare the pdf to the metadata. Any discrepancies will be brought to the 

attention of the index keeper, who will obtain the correct PDF from the ERG 

WAM or project team member, as appropriate. 

• Upload electronic files. 

– Document files can be added at the same time that the document record is 

created, or as a separate step. 

– Use the “create document” wizard to add files. In general, ERG will not 

use the “bulk upload” function. 

– Upload pdf files from ERG’s electronic project file to FDMS. 

– The ERG index keeper will notify docket staff in advance of docket 

activities. 

– As specified by the project, the index keeper or her designee will open the 

uploaded files to confirm they match the metadata. 

• Prepare hard copy material for docket submittal, if necessary. The index keeper 

will try to convert hard copy material into an electronic file, typically by scanning 

and saving the material in pdf format. If the material cannot be converted, the 

index keeper will prepare a hard copy for submittal. This is only expected for the 

following materials: 

– Copyright protected publications; 

– Databases and large spreadsheets on DVD, CD or diskette; 

– Large Books; 

– Physical Objects (maps, and aerial photos);and 

– Other materials as directed by docket staff. 

• Create a document record (metadata) for hard copy material, as described above. 

The document record includes the FDMS document ID. 

• Create a label for the hard copy material. The label must not obscure any 

information. The label should include: 

 Docket number; 

 FDMS Document ID (in pencil); 

 ERG Section number; 

 ERG DCN. 
4-4

• Prepare paper documents as two-sided copies. 

• Assemble all copies in FDMS Document ID order. 

• Place copies in top tab accordion folders. 

• Submit a hard copy list (index) of the documents at the time they are delivered. 

• Deliver hard copy docket materials by Fed Ex, courier or ERG staff to the 

following address: EPA Water Docket, EPA-West Room 3334, 1301 Constitution 

Avenue, Washington, D.C. 20460. 
Attachment 1 

PROJECT FILE OUTLINE 
A1-1

2009 Annual Review and 

Preliminary 2010 Effluent Guidelines Program Plan Docket Subject Outline 

Docket OW-2003-0074 

The following existing sections include the docket materials for the 2004 Effluent Guidelines 

Program Plan. 

Docket OW-2003-0074: Background Documents (includes TSD and appendices) 

Docket OW-2003-0074: Screening Level Review (supporting 2004 Plan) 

Docket OW-2003-0074: Industry Rankings 

Docket OW-2003-0074: Public Comments 

Docket EPA-HQ-OW-2004-0032 

Docket EPA-HQ-OW-2003-0074 

Docket EPA-HQ-OW-2006-0771 

Docket EPA-HQ-OW-2008-0517 

The following sections will be used to organize the docket and project file materials for the 2006, 

2008, and 2010 Effluent Guidelines Program Plans. 

5 No entries 

6 Federal Register Notices, Outreach Materials, and Other Background Documents 

 6.1 Previous Dockets, by reference 

 6.2 Federal Register Notices 

 6.3 Outreach Efforts 

 6.4 Technical Support Documents and Appendices 

7 Public and Inter-Agency Comments 

 7.1 Public Comments on the 2004 Effluent Guidelines Program Plan 

 7.2 Public Comments on the Preliminary 2006 Effluent Guidelines Program Plan 

 7.3 Public Comments on the Final 2006 Effluent Guidelines Program Plan 

 7.4 Public Comments on the Preliminary 2008 Effluent Guidelines Program Plan 

 7.5 Public Comments on the First CBM ICR (January 2008) 

 7.6 Public Comments on the first HCI ICR (August 2008) 

 7.7 Public Comments on the Final 2008 Effluent Guidelines Program Plan 
A1-2

8 CWA §304(g) Review 

Review of the pretreatment standards for industrial point source categories composed entirely or 

almost entirely of indirect dischargers. 

 8.1 Food Service Establishments 

 8.2 Industrial Laundries 

 8.3 Photo-processing 

 8.4 Printing and Publishing 

 8.5 Health Services Industries 

 8.5.1 Independent and Stand-alone Medical and Dental Laboratories 

 8.5.2 Offices and Clinics of Doctors of Medicine 

 8.5.3 Offices and Clinics of Dentists 

 8.5.4 Nursing and Personal Care Facilities 

 8.5.5 Veterinary Care Services 

 8.5.6 Hospitals and Clinics 

 8.5.7 Health Services Industries Economic Information 

 8.6 Independent and Stand-alone Laboratories 

 8.7 Industrial Container and Drum Cleaning (ICDC) 

 8.8 Tobacco Products Processing 

 8.9 Correctional Institutions (Prisons) 

9 Screening-Level Reviews 

 Screening-level review of existing guidelines and standards and new categories. 

 9.1 Analyses of the Toxics Release Inventory 

 Plan, database, QC checks (including telecons) 

 9.2 Analyses of Permit Compliance System data Plan, ICIS-NPDES Data Plan, 

database, QC checks (including telecons) 

 9.3 Other Screening-Level Data Sources NAICS/SIC/Point Source Category 

 Crosswalks 

 9.4 Screening-Level Review Reports 

 QA Project Plans for TRI and PCS Analysis, 

 2005 Screening-Level Analysis Report 

 Nutrients Memo 

 9.5 Toxic Weighting Factor Development 
A1-3

10 Existing Guidelines and Standards Review 

Further review based on National Strategy Factors, of industries with existing guidelines and 

standards, prioritized during screening-level review. The National Strategy Factors are: 1) human 

health and environment hazards; 2) technology innovation and process changes; 3) economics; 4) 

implementation and efficiency considerations. 

10.1 Preliminary Review Reports Review of Prioritized Categories of Industrial Dischargers 

All existing categories are listed below. Potential new subcategories are included with their 

parent category. If no materials specific to a category are collected, the section will be identified 

as “no entries.” Materials collected in support of detailed studies are organized in additional 

sections, following Section 11. 

10.2 Aluminum Forming, Part 467 

10.3 Aquatic Animal Production Industry, Part 451 

10.4 Asbestos Manufacturing, Part 427 

10.5 Battery Manufacturing, Part 461 

10.6 Centralized Waste Treaters, Part 437 

10.7 Canned and Preserved Seafood, Part 408 

10.8 Carbon Black Manufacturing, Part 458 

10.9 Cement Manufacturing, Part 411 

10.10 Coal Mining, Part 434 

10.11 Coil Coating, Part 465 

10.12 Concentrated Animal Feeding Operations, Part 412 

10.13 Copper Forming, Part 468 

10.14 Dairy Products Processing, Part 405 

10.15 Electrical and Electronic Components, Part 469 

10.16 Electroplating, Part 413 

10.17 Explosives, Part 457 

10.18 Ferroalloy Manufacturing, Part 424 

10.19 Fertilizer Manufacturing, Part 418 

10.20 Fruits and Vegetable Processing, Part 407 

10.21 Glass Manufacturing, Part 426 

10.22 Grain Mills Manufacturing, Part 406 

10.23 Gum and Wood Chemicals, Part 454 

10.24 Hospitals Part 460 

10.25 Ink Formulating, Part 447 

10.26 Inorganic Chemicals, Part 415 

10.27 Iron and Steel Manufacturing, Part 420 

10.28 Landfills, Part 445 

10.29 Leather Tanning and Finishing, Part 425 

10.30 Meat and Poultry Products, Part 432 

10.31 Metal Finishing, Part 433 

10.32 Metal Molding and Casting (Foundries), Part 464 

10.33 Metal Products and Machinery, Part 438 

10.34 Mineral Mining and Processing, Part 436 

10.35 Nonferrous Metals Forming and Metal Powders, Part 471 
A1-4

10.36 Nonferrous Metals Manufacturing, Part 421 

10.37 Oil & Gas Extraction, Part 435 

 10.37.1 Coalbed Methane 

10.38 Ore Mining and Dressing, Part 440 

10.39 Organic Chemicals, Plastics and Synthetic Fibers, Part 414 (including Thompson Report 

 response materials) 

 10.39.1 Chemical Formulating, Packaging and Repackaging 

 10.39.2 Biodiesel, Ethanol, and Other Biofuels 

10.40 Paint Formulating, Part 446 

10.41 Paving and Roofing Materials (Tars and Asphalt), Part 443 

10.42 Pesticide Chemicals Manufacturing, Formulation and Repackaging, Part 455 

10.43 Petroleum Refining, Part 419 

 10.43.1 Petroleum Bulk Stations and Terminals (PBST) 

10.44 Pharmaceutical Manufacturing, Part 439 

10.45 Phosphate Manufacturing, Part 422 

10.46 Photographic, Part 459 

10.47 Plastic Molding and Forming, Part 463 

10.48 Porcelain Enameling, Part 466 

10.49 Pulp, Paper, and Paperboard, Part 430 (materials not related to detailed study, e.g., 

 Phase III permit writers support materials) 

10.50 Rubber Manufacturing, Part 428 

10.51 Soaps and Detergents Manufacturing, Part 417 

10.52 Steam Electric Power Generation, Part 423 

10.53 Sugar Processing, Part 409 

10.54 Textile Mills, Part 410 

10.55 Timber Products Processing, Part 429 

10.56 Transportation Equipment Cleaning, Part 442 

10.57 Waste Combustors (Commercial Incinerators Combusting Hazardous Waste), Part 444 

11 Review of Categories Without Existing Guidelines 

11.1 Airport Deicing Operations 

11.2 Water Supply (Drinking Water Treatment) 

11.3 Miscellaneous Foods and Beverages 

 11.4.1 Distilled and Blended Liquor 

 11.4.2 Malt Beverages 

 11.4.3 Soybean Oil Mills 

 11.4.4 Miscellaneous Foods and Beverages Economic Information 

11.4 Liquefied Natural Gas Import Terminals 

11.5 Biofuel Manufacturing 
A1-5

12 Water Pollution Control Technologies, Water Reuse, Water Conservation 

Include information about pollution prevention, wastewater treatment, and other 

 wastewater pollution control technologies that applies to multiple point source 

 categories. Technologies or case studies that focus on one category should be included 

 in the section for the category or detailed study. 

12.1 Water Conservation Issues 

13 Steam Electric Power Generation Detailed Study 

13.1 Study Plans 

 Detailed Study Plan, QA Project Plan 

13.2 Industry Profile 

 Includes pollutants of concern/loadings/sources analyses and relevant articles 

 regarding wastewater characterization issues relevant to key questions" 

 13.2.1 Permit Review 

 Includes memoranda listing relevant facilities and permits selected for review, 

 briefing materials/meeting summaries 

 13.2.2 Pollutant Data 

 Includes monitoring data packages received from plants and monitoring database. 

 13.2.3 Facility Databases and Supporting Documentation 

 Includes facility database, any telecons or other notes to clarify facility data, and 

 change forms. 

13.3 NPDES Permits 

 Includes fact sheets and telecons from follow-up calls with permit writers regarding 

 specific permits 

13.4 Stakeholder Meeting Material 

13.5 Pollution Control Technologies and Their Costs 

 Includes data/articles collected on control technologies (scrubbers, wastewater 

systems), including meetings and requests with treatment vendors. 

13.6 Industry Surveys 

 UWAG Survey 

13.7 Detailed Study Reports 

13.8 Site Visits 

 13.8.1 Site Visit Selection Approach 

 13.8.2 Yates 

 13.8.3 Wansley 

 13.8.4 Widows Creek 

 13.8.5 Conemaugh 

 13.8.6 Homer City 

 13.8.7 Pleasant Prairie 

 13.8.8 Bailly 

 13.8.9 Big Bend 

 13.8.10 Seminole 

 13.8.11 AES Cayuga 

 13.8.12 Mitchell 

 13.8.13 Cardinal 

 13.8.14 Bruce Mansfield 
A1-6

 13.8.15 Roxboro 

 13.8.16 Belews Creek 

 13.8.17 Marshall 

 13.8.18 Mount Storm 

 13.8.19 Harrison 

 13.8.20 Mountaineer 

 13.8.21 Gavin 

 13.8.22 Clover 

 13.8.23 CPS Energy/JK Spruce 

 13.8.24 Fayette Power Project/Sam Seymour 

 13.8.25 Ghent 

 13.8.26 Trimble County 

 13.8.27 Cane Run 

 13.8.28 Mill Creek 

 13.8.29 Brandon Shores 

 13.8.30 Coleman 

 13.8.31 Gibson 

 13.8.32 WVPA - Wabash River 

 13.8.33 Duke Energy - Wabash River 

 13.8.34 Paradise 

 13.8.35 Miami Fort 

13.9 Sampling 

 13.9.1 Sampling Program Planning (Generic SAP, cost estimates, methods/SCC 

 coordination, EPRI information and supplementary data) 

 13.9.2 Episode 6546 

 13.9.3 Episode 6547 

 13.9.4 Episode 6548 

 13.9.5 Episode 6549 

 13.9.6 Episode 6550 

 13.9.7 Episode 6551 

 13.9.8 Episode 6557 

13.10 EPA Data Request Development Files (draft and final DR, meeting notes, EPA and 

 Battelle comments) 

 13.10.1 Mail List Development (company summaries –econ, company lists, 

 directories) 

 13.10.2 Responses 

 13.10.3 Database (dbase development, data entry QC, data element dictionary, 

 tables/queries) 

13.11 Technology Options, Costs, and Loads 

 Includes EPA's analyses, documentation, and memoranda related to defining options, 

 estimating facility and industry costs, and estimating facility and industry loads. 

13.12 Environmental Assessment Documentation 
A1-7

14 Tobacco Products Processing Detailed Study (closed as of December 2006) 

14.1 Study Plans (Detailed Study Plan, QA Project Plan) 

14.2 Industry Profile (include information on companies and individual plants) 

14.3 Site Visits, Sampling and Analysis (include pre-sampling telephone contact reports) 

14.4 Pollution Control Technologies and Their Costs 

14.5 Detailed Study Reports 

14.6 Tobacco Products Economic Information 

15 Pulp, Paper, and Paperboard Detailed Study (closed as of December 2006) 

15.1 Study Plans (Detailed Study Plan) 

15.2 Industry Information 

 Meeting summary, AF&PA disputed loads letter with enclosures, AF&PA minimum 

 monitoring letter with enclosures, Mill discharge data (i.e., minor discharger, 

 Washington mills), Phase I Mill Industry Profile. 

 Draft TRI Guidance Document, TAPPI paper Comparing Chlorinated Phenolic 

 loadings 

 15.2.1 Pulp and Paper Industry Economic Information 

15.3 Quality Review 

 Designation of SIC codes into Phase, Changes to Phases, telecons (i.e., Kimberly-

 Clark Everett WA, Weyerhaeuser surface impoundment, IP-Cantonment Permit 

 Status) 

15.4 NPDES Permits (Includes factsheets and communication from mills that defined 

 outfalls) 

 15.4.1 Phase I mill permits 

 15.4.2 Phase II mill permits 

15.5 Detailed Study Reports 

16 Coal Mining Detailed Study 

16.1 Study Plans (Detailed Study Plan, QAPP) 

16.2 Industry profile for the coal mining industry 

16.3 Pollutant loads 

 Data Obtained from states and IMCC 

 Pollutant Loads Concept Memo 

 Loads spreadsheets and results 

16.4 Treatment technologies and costs 

 Model mine memo, AMD Treat review, costing spreadsheets and results 

16.5 Environmental assessment 

 Memos addressing “Key questions” 

 Articles collected related to impacts of manganese 

16.6 Flight 93 Memorial Site Information 

 Joanne Hanley e-mails, Lenny Lichvar document, PBS Coals letters 

16.7 Non-CWA Regulations (SMCRA, Other Federal, and State Laws) 

16.8 Economics, Bonds, and Trust Funds 
A1-8

17 Health Care Detailed Study 

17 Health Care Detailed Study 

17.1 Study Plans and Reports 

17.2 Dental Hg Industry Profile and Background Information (including wastewater 

 characteristics, regulations, guidance) 

17.3 Dental Hg BMPs, Control Technologies, and their Costs 

17.4 Dental Hg POTW Treatment Efficiencies, pass through, and interferences 

17.5 Dental Hg Economic Information 

17.6 Dental Hg Meetings 

17.7 Unused Pharmaceuticals Industry Profile and Background Information (including 

wastewater characteristics, regulations, guidance) 

17.8 Unused Pharmaceuticals Data Request and Responses 

17.9 Unused Pharmaceuticals BMPs, Control Technologies, and their Costs 

17.10 Unused Pharmaceuticals POTW Treatment Efficiencies, pass through, and 

interferences 

17.11 Unused Pharmaceuticals Economic Information 

17.12 Unused Pharmaceuticals Meetings and Site Visits 

18 Coalbed Methane Detailed Study 

18.1 Plans 

18.2 Stakeholder Meetings 

18.3 Site Visits/Sampling 

18.4 Industry Survey Development and Distribution 

 18.4.1 Questionnaire Development 

 18.4.2 Survey Sampling Strategy includes development of mailing list 

 18.4.3 Information Collection Request includes burden estimate, drafts of ICRs 

18.5 Industry Survey Results 

 18.5.1 Responses raw completed questionnaires 

 18.5.2 Database(s) 

18.6 Technical Background Information 

 18.6.1 Produced water quality and volume data 

 18.6.2 Reuse and Treatment Technologies technology performance and costs 

18.7 Economic Background Information 

18.8 Environmental Assessment Background Information 

18.9 Detailed Study Reports 
A2-1 

Attachment 2 

304m PROJECT FILE LOG-IN FORMS 
A2-1 

This page illustrates the electronic Microsoft Excel spreadsheet, with dropdown menus available for auto-population of some fields. The second page showMicrosoft Excel or Word. 

Example Blank Microsoft Excel Login Sheet 

Example of Login Sheet Drop-Down Menu 

Example Completed Microsoft Excel Login Sheet 
A2-2

304(m) ELECTRONIC PROJECT FILE INDEX LOG-IN SHEET 

 Submitted by: 

 

DCN: Index Keeper will assign DCN 

 

 

 

TITLE: 

 

 

 

 

ABSTRACT: 

 

DOCUMENT_SUB TYPE: 

SOURCE_CITATION: 

AUTHOR: 

AUTHOR_DATE: 

PAGE_COUNT: 

CATEGORY_INDUSTRY: 

COPYRIGHT PROTECTED (Yes or No): 

CBI (Yes or No): 

NPDES_PERMIT_ID: 

TRI_ID_NUMBER: 

KEYWORD_1: 

KEYWORD_2 

ELECTRONIC COPY FILE 

LOCATION: 

DOCKET_ITEM (Yes or No) 
Attachment 3 

FDMS GUIDELINES FOR FREE TEXT FIELDS 
A4-1

Guidelines for Free Text FDMS Metadata 

Information for free text fields should be recorded in a consistent format to ensure reliable 

retrieval. 

The guidelines described below cover the most common types of errors: grammar, abbreviations, 

capitalization, use of numerals, and punctuation. Two additional areas where errors are 

likely to be generated include spelling and typographical formatting. Use of spell 

checking software and proofreading entered data can reduce spelling errors. 

Typographical or formatting errors can be caused by sloppy cut and paste functions, 

forgetting to close a parenthetical expression, or failing to use quotation marks correctly. 

These errors can be addressed by using grammar checking software and, again, carefully 

proofreading data entry. 

Within the FDMS system, the Document ID, Document Title, and Document Type are 

searchable fields. The search fields are case sensitive. Document Title is a free text field, 

so special care for consistency in capitalization must be taken with this field. If the user 

searches on a term using a mix of upper and lower case letters, the database will only 

return results that match that specific mix of characters. Searches performed using letters 

of a single case will return results regardless of specific character combinations. Since 

users are most likely to use a mix of upper and lower case letters with proper names, you 

must be sure that the metadata are entered in the correct format for a proper name. 

Guidelines are included below on the use of abbreviations, capitalization, numerals, and 

punctuation. Additional resources that can be used in making formatting decisions 

include dictionaries and the MLA Handbook for Writers of Research Papers, Sixth 

Edition (2003). 

I. Grammar Review 

The same careful thought given to writing a memorandum or a letter should be used when 

composing metadata. Fields such as Abstract are designed to allow the data entry 

operator to present information using anywhere from a single sentence to a full 

paragraph. It is important, therefore, that this information be presented in proper syntax 

using complete sentences. Run-on sentences should be avoided. As with any free text 

field, it is important that the data be presented in a way that other readers will find clear 

and concise. Since space in the field is limited, you may need to redraft text to fit within 

the parameters of the field. When doing so, it is important be sure that all unnecessary 

characters have been removed and that the new text conforms to the flow of the existing 

sentences. 

II. Abbreviations

Abbreviation styling is, unfortunately, inconsistent and depends most often on the organization’s 

policy. Company names are especially arbitrary as many businesses desire a unique look 

and feel to distinguish their name and letterhead from other firms. For example, Gulf + 

Western Industries, Inc. is the actual company name. This firm selected to represent the 

word “and” not with the more traditional “&” but with a positive or plus sign “+”. In 

such cases, you should default to the official name as presented by the organization. 
A4-2

Abbreviations are used for many reasons in document development. The most common reasons 

include (1) to avoid repetition of long words and phrases that may distract the reader, (2) 

to save space and time, (3) to replace keystrokes and increase output, and (4) to reflect 

statistical data in limited space. When using an abbreviation that may be unfamiliar or 

confusing to the reader, one should give the full form first followed by the abbreviation in 

parentheses as 

 Summary of Orders from the Office of Management and Budget (OMB)..... 

followed in subsequent references by just the abbreviation, as 

 At the June 14, 2003, OMB meeting, agents met to discuss...... 

When abbreviating an Agency employee’s various program affiliations, it is acceptable to use 

virgules. For example: Dave Beck, USEPA/ESED/CPB/CM 

If a position title had been provided, the proper format would have been: Dave Beck, Regulatory 

Analyst, USEPA/ESED/CPB/CM 

Guidelines for Abbreviations

The only terms which do not require use of the full form before the use of the abbreviation are 

those business units within the U.S. Environmental Protection Agency or the agency 

name itself. 

If the full form and abbreviation are used in the docket or document title field, then the 

abbreviation may stand alone in the docket or document description field. 

Guideline Sample

The Environmental Protection Agency should 

be abbreviated according to Agency 

Standard. 

USEPA 

Beginning a sentence with an abbreviation 

should be avoided unless the 

abbreviation represents a courtesy title.

Page 22 contains.... but not P. 22 contains .... 

Dr. Smith is here. or Doctor Smith is here. 

Company names are not abbreviated unless 

abbreviations comprise their official 

name. 

Ginn and Company 

Harwood Engineering Co., Inc. 

Compass points are abbreviated when 

occurring after street names and they 

can be unpunctuated. 

2122 Apple Street, NW 

Geographical and topographical names should 

utilize U.S. Postal Service 

abbreviations. 

AL AK MN DC 

BLVD ST PL RR US 

Laws and bylaws when first mentioned are 

typed in full; however, subsequent 

references may be abbreviated. 

first reference Article I, Section 1 

subsequent reference Art. I, Sec. 1 
A4-3

Guidelines for Abbreviations

Personal names should not be abbreviated. George S. Patterson not Geo. S. Patterson 

Scientific terms in binomial nomenclature 

may have the genus abbreviated after 

the first full form reference. 

first reference Escherichia coli 

subsequent reference E. coli 

Titles that are invariably abbreviated include 

Mr., Mrs., Ms., Messrs., and Dr. 

Honorable and Reverend when used 

with The are typed out. If used without 

The, these forms of address may be 

abbreviated. 

Colonel COL John P. Howe, USA 

General GEN John P. Howe, USA 

Private PVT John P. Howe, USA 

Versus is abbreviated as the lowercase Roman 

letter v. in legal contexts. In general 

context, it is abbreviated as vs. 

Smith v. State of Vermont 

honesty vs. dishonesty 

III. Capitalization 

Upper case letters are used for two broad purposes in English: they mark the beginning of a 

sentence and they signal a proper noun or adjective. Keeping mind that the database’s 

search function are case sensitive, it becomes even more critical for you to apply the rules 

of capitalization accurately. 

Guidelines for Capitalization

Abbreviations are only capitalized if the words they represent are proper nouns or adjectives. 

The first word of a sentence, of a sentence fragment, or of a complete sentence enclosed in 

parentheses is capitalized. 

Guideline Sample

Most acronyms are capitalized unless they 

have been assimilated into the 

language as parts of speech. 

Consult a dictionary for proper styling. 

Acronyms that are not part of the daily 

language: MIRV NOW account 

Acronyms that are used as part of the daily 

language: scuba, quasar, laser, radar, 

sonar, snafu 

Abbreviations of air force, army, coast guard, 

and navy ranks are all capitalized. 

Those of the marine corps are 

capitalized and lower cased. 

BG John P. Howe, USA 

LCDR Mary I. Lee, USN 

Col. John P. Howe, USMC 

Abbreviations of academic degrees and 

professional ratings may be all 

capitalized or capitalized and lowercased depending on the term. Consult a 

dictionary for proper styling. 

D.D.S. M.B.A. 

P.E. C.P.A. 

Ph.D. 
A4-4

Guidelines for Capitalization

Branches and units of the armed forces are 

capitalized, as are easily recognizable 

short forms. 

United States Army and Army Rangers 

Popular names of localities are capitalized. Capitol Hill Foggy Bottom 

Georgetown the Sunshine State 

the Corn Belt the Eastern Shore 

Nouns used with numbers or letters to 

designate major reference headings are 

capitalized; however, minor reference 

headings and subheads are typically 

lowercased. 

Book II Volume V Part 1 

Table 5 Figure A Appendix III 

footnote 14 page 12 line 8 

item 16 note 10 paragraph 7 

Words in titles of printed matter are 

capitalized except for internal 

conjunctions, prepositions, and 

articles. 

Introduction to Word Processing 

Before the Fall 

Journal of Scientific Medicine 

The first word following a colon in a title is 

capitalized. 

CBS: Reflections in a Bloodshot Eye 

Women in Baseball: The Forgotten History 

Trademarks, brand names, and service marks 

are capitalized. 

the Dell workstation Federal Express 

Touch-Tone 

The names of ships, airplanes, and spacecraft 

are capitalized. 

space shuttle Columbia 

Spirit of St. Louis 

M. V. West Star 

 

IV. Numerals 

In modern business writing, most numerals - and especially exact numbers above 10 - are 

expressed in figures. Since there is flexibility in expressing monetary units, dates, and 

other numerical combinations, the overriding consideration is to be consistent in the 

standard selected. Provided below are the standards selected for use of numerals in the 

FDMS database. 

Guidelines for Numerals 

Guideline Sample

Ages are expressed in figures. Her 11 year-old son... A 65 year-old veteran...

Space permitting, numbers that begin a 

sentence are to be written out. 

Thirty-two birds died. 

Dates should be written as Month, Day, and 

Four Digit Year when expressed in 

narrative format. Ordinal numbers 

should not be used. 

January 1, 2003 

 not 

the 1st of January, 2003 
A4-5

Guidelines for Numerals 

Guideline Sample

Dates may be represented in figures when not 

in narrative format but must be in the 

format of MM/DD/YYYY. 

11/21/2003 

Exact amounts are usually expressed in figures 

unless they begin a sentence. 

Thirty-two birds died. 

Due to the chemical spill, 32 birds died. 

Percentages will use the % character. 10 % not 10 percent 

Figures over 999 will use a comma except 

when the number is a set combination 

such as a contract number, policy 

number, check or invoice number, 

address or room number. 

1,135 keystrokes not 1135 keystrokes 

Check 34567 the year 2003 page 4526 

Room 6000-B Contract No. W-03-12456 

V. Punctuation 

The English writing system uses punctuation marks to separate groups of words for meaning and 

emphasis; to convey an idea of the variations of pitch, volume, pauses, and intonation of 

speech; and to help avoid contextual ambiguity. Punctuation marks should be used 

sparingly as special characters can make searching for and retrieving data difficult. 

Spacing is an important issue in the use of special characters. There should be no space between 

the following combinations: any word and the punctuation that closes a sentence, 

quotation marks and the quoted matter, parentheses or brackets and the words or figures 

that they enclose, between initials comprising abbreviations, between hyphenated 

compounds, or on either side of a dash. There should be one space after a comma or 

semicolon, after a period following an initial in a proper name (Mr. H. C. Milker), before 

and after mathematical signs, and between U. S. Postal Service state abbreviations and 

the ZIP Code. 

Guidelines for Punctuation

Virgules (/) are not used to separate items in a list or to divide phrases but can be used if it is 

part of a title or acronym. (E.g. OEI/OIAA) 

Use of the ampersand (&) should be avoided whenever possible. Spell out the word “and” 

instead. Use of the ampersand is permissible when it is a part of a proper noun such as a 

company name or is part of a legal case title or publication title. 

Hyphens/dashes (-) are not used to introduce a list of items. 

Ellipses (...) are used when a title or quote is to long to fit within a field. 

Guideline Sample

While apostrophes normally mark the 

omission of numerals or letters, this use 

should be avoided in the FDMS database 

where the electronic record will be retained 

indefinitely. 

the class of 1967 not the class of ‘67 

fiscal year 1987 not fiscal year ‘87 
A4-6

Guidelines for Punctuation

Apostrophes are used in possessive nouns. One Man’s Junk 

The History of the Thirty Years’ War 

Brackets set off extraneous data and function 

as parentheses within parentheses. 

The company deceived them [the suspects] 

and is now paying hefty penalties. 

(Bowman Act [also known as the Freedom 

Act] Ch. 4, sec. 4, p. 50) 

Colons introduce a clause or phrase that 

explains, illustrates, amplifies or restates what 

has gone on before. 

The Hazards of Benzene: An Inhalation Study 

Colons introduce items in a series. Please reference the following dockets: OAR2002-0012, OAR-1999-0014, and 

OW-2001-0142. 

Colons separate elements in set formulas such 

as ratios, time, volume and page references, 

biblical citations, and place and publisher. 

a ratio of 3:5 8:30 a.m. 

Words and Phrases 11:261 John 4:10 

Springfield, MA: Merriam-Webster Inc. 

Commas divide items in a list and set off cities 

from states, dates from years, and lines in an 

address. 

...includes: OAR-2002-0012, OAR-1999-

0014, and OW-2001-0142. 

Shreveport, LA December 7, 2003 

Hyphens are used only in numerical sets 

where dictated by style. 

OAR-2003-0012 

Contract No. W-03-125-8954A 

Hyphens are used between some prefix and 

root combinations. 

Consult a dictionary for proper styling. 

trans-Atlantic flight 

pre-2003 

re-publish 

non-road 

Hyphens are used in compound words, 

especially those containing a preposition. 

Consult a dictionary for proper styling. 

chairperson-elect attorney-at-law 

Hyphens are used between compound 

adjectives. 

light-duty large-scale 

eight-cylinder 

Hyphens are used in expressing written out 

numbers, between a numerator and 

denominator, dividing years and pages in a 

range, or showing a distance relationship. 

forty-two flowers 

a two-thirds majority 

pages 40-67 

the decade 1960-1970 

US-Iraq relations 

Ellipses (...) are used when a title or quote is 

too long to fit within the field. 

The organization replied that it “felt 

overwhelmed by the workload required 

under...the Clean Air Act.” 
A4-7

Guidelines for Punctuation

Alternative spellings of English terms should 

be retained in formal titles and affiliations. In 

FDMS, include the American spelling of the 

term in brackets after the foreign language

spelling. 

Consult your dictionary for the proper 

American spelling. 

organisation [organization] 

colour [color] 

centre [center] 

glycerine [glycerin]