# APPENDIX VI

### ) RCRA DATA MANAGEMENT I.ETTER OF AGREEMENT BETWEEN IDAHO DEPARTM ENT OF ENVIRONMENTAL QUALITY

WASTE MANAGEMENT & 

### REMEDIATION DIVISION AND US EPA REGION 10 OFFICE OF WASTE & 

### CHEMICALS MANAGEMENT This document defines the terms and responsibilities for managing data for both the U. S. EPA Region 10 

### (EPA Region 10) 

### and the Idaho Department ofEnvironmental Quality (Idaho DEQ) under the Resource Conservation and Recovery Act (RCRA) Program. The data referred to reside in the Resource Conservation and Recovery Act Informati on System (RCRAlnfo), willch now includes Hazardous Waste Report data (from the former Biennial Reporting System). Th.is document replaces the previous RCRIS Memorandum ofUndorstanding (MOU)

. 

### RCRAlnfo is an automated information management system for the storage, tracking, and analysis of data relating to state and federal hazardous waste program activities. The database provides inf ormation needed to support the implementation of RCRA , as well as provides information needed by EPA Headquarters to support their functions

. EPA Region 10 and Idaho DEQ equally share access to RCRAlnfo

. There is no "Implementer of Record". EPA Region 10 

### and Idaho DEQ users with edit access are able to change any data, except where agreed upon within this document
. EPA Region 10 

### will not change handler data, since handler data is entered directly into RCRAlnfo by Idaho DEQ

. This document upholds the following basic principles:

• Serves as th e official agreement between EPA Region 10 

### and Idaho DEQ by identifYing the areas of information management associated with maintaining RCRAIofo data; • Clarifies RCRAlnfo data management requirements and procedures; • Improves patmering, information sharing and the quality ofRCRAlnfo data; • Provides a formal procedure for resolving di sputes over the content ofthe data

. General Aereemeols : EPA Region 10 and Idaho DEQ agree to share all data within the RCRAlnfo handler, compliance/monitoring/enforcement, permitting, corrective action, and waste acli,ity modules

. The responsibility f or entering hazardous waste data is th at of the Agency performing the data collection. Data will be entered within the ti me frames specified for each module The data tbat must be entered by EPA Region 10 

### and Idaho DEQ is the "Systemrequired" or "Nationally required" data as defined by the most current versi on ofthe RCRAJnfo Data Element Dictionary (DED). Staffing: Idaho DEQ will appoint onE person 10 

### be the primary data contact for RCRAlnfo data management, including the national Hazardous Waste Report cycle

. This person will function as the teclmical contact and State Data Administrator (SDA). The SDA will be responsible for communicating witb EPA Region lOon issues related to RCRAInfo

. In addition, the SDA will



# !IIIIIII nil 1 1111 1111 1 111 10264

: OWRPbe responsible for making sure Idaho DEQ users are trained, documentation is kept up-to-date, QAJQC is performed according to established time [Tames, all data is entered or sent to EPA Region 10 in a timely manner, required reports are able to be printed, and guidance is provided to State Managers on data-related policy issues. Regional Role: EPA Region 

### 10 will assist Idaho DEQ in maintaining the national database, provide assistance with access to Idaho DEQ users, develop/share agreed-upon reports, and conduct data oversight duties including the development and negotiation ofpolicies related to national issues. All policies developed will aim toward national consistency and equity for Region 10 States.
Communications and Relationships: EPA Region 10 and Idaho DEQ data entry and programmatic staff should work together to ensure that RCRAInfo data management is successful. The EPA Region 10 RCRAlnfo Systems Administrator (RSA) will assist and suppor1 both staff when problem-solving and in interpreting RCRAlnfo requirements. EPA Region 10 and Idaho DEQ agree to consult with each other frequently about data decisions that are new or unusual and any decis.ions that affect the calcul ated universes. Data Quality: Both Agencies will strive to keep data as accurate and error-free as possible by submitting all "System-required" and "Nationally Required" data and by conducting regular QAJQC activities. These activities will include, but not be limited to the following: verification ofreal-time data with hard-copy files; review ofpermitting and corrective action reports for activity completeness; unresolved violation reviews and updates; and Idaho DEQ staff reviews of ) facilities as requested by EPA Region 18 stnff. In addition to discussions with EPA Region 

### 10, Idaho DEQ will use RCRAInfo's On-line Help and/or DED for questions on data usage. Only activities entered into RCRAlnfo will be counted as completed. The responsibility for conecting data problems will be negotiated between the two Agencies with regard to efficiency and acceptability.
ElectTonic Data Access: RCRAlnfo User IDs will remain the san1e as those used in the RCRJS mainframe if the user was established prior to the transition to the new system. New users will contact EPA Region 10 to establish a User ID. Idaho DEQ will access RCRAInfo via an Internet secure site connection. Idaho DEQ may be required to access the secure site with a compatible version ofInternet Browser software.
RCRA Identification Number**Is§uanc~:** Idaho DEQ has primary responsibility for the Handler module, including the generation and issuance of H azardous Waste ID numbers (ID numbers) accomplished by completing an "N"or "I" record. ID number issuance will occur within 

### 10 days ofreceipt ofa completed RCRA. Subtitle C Site Identification Forn1 [8700-12] or State equivalent form. Idaho DEQ will issue new ID numbers, update, inactivate, reactivate, and verify existing ID numbers for all regulated handlers. When necessary, EPA Region 10 and Idaho DEQ will establish and LIse an agreed-upon programmatic process to come to agr eem ent on a ReRA handler status that is entered in the database.

2"State-only' Hazardous Waste 

### ID Numbers: In addition to being responsible for issuing 

### "0) nwnbers to RCRA regulated handlers, Idaho DEQ may use the database to track handlers who are regulated under Idaho's own hazardous waste rules as long as the associated ID numbers begin with the State's own postal code. "State-only" handlers in RCRAlnfo must be readily discemable as being tracked for State purposes only and may be tracked in all appropriate modules.
Non-Notifier 

### ID Numbers: Idaho DEQ is responsible for entering non-notiflcrs it discovers into the RCRA1nfo handler module as an "1" record when generating a non-notifier ID number. The accompanying inspection that "discovers" the non-notifier should also be entered into the Compliance, Monitoring, and Enforcement module. Tribal Sites: EPA Region 10 has the authority for regulating entities within the federallyrecognizcd Indian reservation boundaries. Howevcr, Jdaho currently has a number ofsites that would appear to be within those boundaries that have not been previously designated as tribal based on the land and/or owner type. Until such time as Idaho and EPA Region 10 can determine an offi cial list of existing

. 1D number sites to be tumed over to EPA for regulatory authority, Idaho DEQ will continue to process EPA ID munber requests as usual (at the request ofEPA Region 10), Nomenclature: The Idaho DEQ site naming process will be consistent with EPA's standard nomenclature policies as established in the Facility Index System (FINDS) and EPA Region 10 

# ) Federal Facil ity Nomenclature Standard. This will ensure that the data drawn from national systems to respond to EPA and Idaho DEQ staffreporting needs, and the data used to populate public databases (such as Envirofacts, ECHO/OTIS), sorts properly and is easy to pull.
TSD Universe Calculations : Because ofthe Government Performance Results Act (GPRA) implications and RCRAlnfo Universe calculations , both Agencies will consult with one another before making any changes to the TSD universe. This can be done at quarterly meetings. on conference calls, by official mail, or any agreement documented to the other Agency and placed into the handler's physical file

. In RCRAlnfo, the official universes will be those calculated by the model described in the RCRA1nfo DED. Documentation: Idaho DEQ will maintain complete physical and/or electronic files on each handler issued a RCRA LD number. Copies of all forms or documents submitted to Idaho DEQ that change handler site identification information, especially name and status changes, will be sent to EPA Region 10 monthly

. Idaho DEQ will document and share its data management practices with EPA Region 10. These documents should contain, but are not limited to, Idaho DEQ's Standard Operating Procedures (SOPs) for data collection and management, Slate defined codes used in RCRAInfo, and data QAJQC activities with schedules and time lines. The documents will be resubmitted to EPA Region 10 when revisions occur to the originals.

3CompliancelMonitoringlEnforcement (CM&E): Idaho DEQ will review its CM&E data annually or as needed to resolye site-specific data questions. Updates to the CM&E module of RCRAJnfo will be entered within 30 days ofthe action taken. The State's umesolved violations will be reviewed quarterly by Idaho DEQ and all aetivities related to these uruesolved violations updated. EPA Region 10 and ldaho DEQ will make continuous efforts to coordinate all compliance, enforcement, and inspection data.
EPA Region 10 and Idaho DEQ will jointly decide which RCRAlnfo CM&E reports will be used to assess and manage data within the CM&E module. Whichever Agency's reports are selected, that Agency will make the reports available to the other Agency quarterly via hardcopy or report menu selection. Both Agencies will incorporate these reports into their regular data analysis

. Permitting/Closure: Data received on Hazardous Waste Permit Information (8700-23 Part A) forms will be processed and entered into RCRA lnf o by Idaho DEQ no more than 30 days after receipt. Where the State does not have regulatory authority, Idaho DEQ will send the Part A information to EPA Region 10, who will enter it into RCRAInfo within 10 days ofrecei pt. All State activities related to the RCRAlnfo Permitting/Closure module will be entered within 30 days after they occur. Idaho DEQ will establish and maintain a process to assure that each pe rmit writer will review data for each facility they are responsible tor on a quarterly basi s and submit revisions to the SDA for data input

. EPA Region 10 and Idaho DEQ will jointly decide which RCRAInfo Permitting reports will be used to assess and manage data within the Permitting module. Whichever Agency's reports are selected, that Agency will make the reports available to the other Agency quarterly via hardcopy or report menu selection. Both Agencies will incorporate these reports into their regular data analysis. Corrective Action : All State activities related to the Corrective Action Module will be entered within 30 days after they occur. Jdaho DEQ will establish and maintain a process to assure that each corrective action/closure lead will review data for each facility they are responsible for on a quarterly basis and submit revisions to the SDA for data input.
EPA Region 10 and Idaho DEQ will jointly decide which RCRAlnfo Corrective Action reports will be used to assess and manage do to within the Corrective Action module. Whichever Agency's reports are selected, that Agency will make the reports available to the other Agency quarterly via hard copy or report menu selection. Both Agencies will incorporate these reports into their regular data analysis. Annual aod Biennial Reportine : Idaho DEQ will collect, process, and enter State annual reporting and federal biennial hazardous waste reporting data according to each required schedule. State annual generator reports are due every January 31 for the previous reporting year by Large and Small Quantity Gene,ators

. The Idaho Hazardous Waste Management Report is due to the Governor and Jdaho Legislature by March I. Federal biennial reports are due March 1 of every even-Jlumbered year for the previoas odd

-numbered reporting year by Large Quantity Generators and Treatment, Storage, Disposal Facilities. Biennial report data will be on-time and



### 4') free of errors prior to transmittal to EPA Region 10 for the national Hazardous Waste Report, fonnerly known as the BRS reporting cycle

. Dispnte Resolution: EPA Region 10 and Idaho DEQ agree to follow the procedure detailed below to resolve disputes. Whenever data problems occur, the Agency identifying the problem will be responsible for providing all pertinent data 10 the other Agency. EPA Region 10 and Idaho DEQ agree 10 reso lve dispules at the slafflevel whenever possible

. Once the elements of a dispute have been identified, the Agency ident ifying the items will contact the other Agency to discuss the data in question. If staffcannot resolve the problem, it will be escalated to the Unit/Section management level for resolution. If it is determined that res olution cannot be reached at the first management levels of both Agencies, the problem wili be escalated to the nqt level of management for a review/decision until it reaches the highest management level. Final authority for dispute resolution will rest with the EPA Director ofthe Office orWaste and Chemical Manflgemcnt and Ihe Waste Management and Remedjalion Division Administrator with Idaho DEQ. Both Agencies agree that the maximum time frame for resolving any RCRAlnfo related issue will not exceed 30 days from the date ofproblem identification

. Amendment: Should there be any significant changes in RCRA Policy, the States relationship to EPA Region 10 in terms of Authorization, or substantial enhancement/modification to the database system, EPA Region 10 and Idaho DEQ agree U,at this document may be amended to add provisions that ensure the timely management of quality data in RCRAlnfo. This agreement does not affect the legal rights that either party has, nor does it provide any rights to non-signing facilities or persons . Once signed, this document will continue to be in effect until modified by mutual consent. Signatures: The individuals signing below agree to ensure that RCRAlnfo data management is properly administered by EPA Region 10 and Idaho DEQ. Any issues not covered by this agreement will default to the RCRA Program Memorandum of Agreement. US Environmental Protection Agency Region 10 Idaho Department of Environmental Quality Office of Waste & Chemicals Management Waste Management & Remediation RCRA Program HWMA Program 

# 7

# 1:~6'**V~ ~**  Brian Monson, Manager

Date Date 

### RECEIVED



## JUN 2 3 2003

OEO S TATE WASTE W>.NAGfIIOO 

### i fl!MEl)'.A]QN OIVISION 

### 5