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'11"11'" III" 11'11'1'1' II

ECOLOGY

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POLICY 3-6 RCRIS IMPLEMENTATION ROLlS AND RESPONSIBILITIES

This policy describes the responsibilities of Solid and Hazardous

Waste Program sections in implementing the RCRIS data management

system.

1. The Hazardous Waste Information and Pl,nning Section Will pevelop,

Imp1emene. and Provide Technical Support for RCRIS

The Hazardous Waste Information and Planning Section will be

responsible for the following activities:

o Developing and revising the RCRrS Implementation Plan

o Coordinating all RCRrs training with the EPA

o Providing RCRIS data management support to the regions

o Conducting final QA/QC on merged statewide data before

transmittal to EPA Region 10

o Electronically transmitting data, collected by Ecology, to

Region 10 EPA on a regular basis

o Electronically .transmitting RCRrS data, collected by EPA

. Region 10, to SHW headquarters; regional offices will

receive data from headquarters

o Conducting RCRIS database functions pursuant to RCRIS

Interagency Agreement

o Providing RCRIS data in response to informal data requests

from federal, state, or local entities ~nd other Ecology

programs

2. The Hazardous Waste pevelopment and Support Section has

Coordinating and Negoeiating Responsibilities in Implementing

RCRIS

The Hazardous Waste Development and Support Section will be

res~onsible for the following activities:

o Negotiating agreements with EPA including, (1) RCRIS

Interagency Agreemene, (2) Implementor of Record (lOR),

and (3) Facility management Plans (FKPs) with the regional

3-6-1
POLICY 3-6 RCRIS IMPLEMENTATION ROllS AND RESPONSIBILITIES

.. office. (tracking FMPa in RCRlS is optional).

o Coordinating with EPA on reporting requirement.

o Tracking State/Environmental P~otection Agency Agreement

commitments

o Coordinating RCRIS project pursuant to the RCRIS Interagency Agreement

3. The SHY Regional Offices. Hanford. Industrial. and the Permit

Section Vili Input and Manage BCalS Data

The SHW regional offices, Hanford, Industrial, and the Hazardous

Waste Permit Section will be. responsible for the following

activities:

o Inputting regional facility data into RCRIS on a regularly

scheduled basis as established in the RCRIS Implementation

Plan

o Preparing data assessment reports on the regional data

base (QA/QC)

o Transmitting data to and receiving data from SHW headquarters on a regularly scheduled basis as established

in the RCRlS Implementation Plan

o Retrieving regional data (e.g. to produce tickler reports

on noncompliant companies or to plan inspections using

notification data found in handler identification modules)

4. The Program Support Section Vill Provide Computer Applications

Support

The Program Support Section will be responsible for the following

activities:

o Providing RCRIS application functions such as equipment

configuration, software installation, delivery of systems

to regional offices and connecting all peripherals (CIC

functions)

o Assisting in FOCUS programming for special user needs

o Providing assistance for RCRlS user training

APPRO~ BY: • \\AI~\4<? £tfr~ DATE: 3/?dIlt a:

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RCRIS·

MEMORANDUM

OF

UNDERSTANDING

BETWEEN

U.s. ENVIRONMENTAL PROTECTION AGENCY

REGION 10

AND

WASHINGTON DEPARTMENT OF ECOLOGY

November 1990
INTRODUCTION

.This Memorandum of Understanding (MOU) represents agreements between

Washington State Department of Ecology (Ecology) and EPA Region 10 (Region 10) 0

regarding all components of Resource Conservation and Recovery Act Information

System (RCRIS). This includes the Implementor of Record (lOR) designation and the

standard protocols for system operation.

The purpose of the MOU is to define the terms and responsibilities for managing data.

RCRIS was developed to provide an automated information management system for the

storage, tracking, and analysis of data relating to state and federal hazardous waste

program activities. The system is designed to provide information needed to support

Ecology and Region 10 in implementing the Resource Conservation and Recovery Act

(RCRA), as well as information needed by Region 10 and EPA Headquarters for their

oversight functions.

As a result of co-imp1ementation of the RCRA program. both Ecology and Region 10

will maintain separate RCRIS implementer data bases. When merging the information

from these two data bases, it is necessary to ensure the integrity of the data generated by

either Agency by designating which Agency will be the lOR of the data.

This MOl: upholds the following basic principles:

1. The MOU serves as the official agreement between Ecology and Region 10 for

managing RCRIS data. o

2 An lOR designation will be assigned to all RCRIS data elements. The agency

responsible for the work, owns the data, and is. the lOR for that data. These

assignments will be held on file at both Ecology and Region 10. lOR designations

can only be modified by mutual agreement, on an as needed basis.

3. Single and multiple view data will be accommodated

TERMS OF AGREEMENT

1. EPNState Cooperation in System Development/Maintenance

Consistent with National EPA/State Data Management goals, Region 10 will act

as an advocate for State-requested enhancements to RCRIS. Region 10 "ill share

with Ecology any technical information on proposed changes to RCRIS. Changes

to the data entry, transfer, and retrieval procedures will be quickly communicated

and followed by additional guidance, if necessary. Through the State EPA .

Agreement (SEA) workplan, funding for staffing, operating costs, and training for

Ecology will be part of the yearly gr~

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2 Data Entry and Quality

Ecology is considered a "Full RCRIS User" because RCRIS will be their principle

hazardous waste information system. As a full RCRJS user, they will electronically

enter RCRA information directly into RCRIS. Ecology will assume responsibility

for the quality, timeliness, and accuracy of state entered data; however, EPA is

ultimately responsible for the oversight RCRIS data.

3. Data Management Responsibilities

Ecology will appoint a RCRIS Project Officer (PO) who will meet the

responsibility for data quality, timeliness, and accuracy and is responsible for

overall system administration. A Region 10 PO will have similar responsibilities.

The PO's will maintain a close working relationship to assure timely and accurate

data and to promptly address issues affecting RCRIS data sharing. PO's are

responsible for informing all appropriate managers and system users, in a timely

manner, of any changes or modifications.

Region 10 and Ecology will appoint a Data Base Administrator (DBA) to

implement the details of this agreement DBA's will work with the day-to-day

management issues outlined in this MOU. They will inform the PO of changes in

the data dictionary (data elements and definitions), data handling protocols, lOR

basic principles, merging of state and federal RCRIS data bases, changes to data

base records, quality assurance/quality control of the data, distribution of upgrades

and enhancements of the RCRIS software, and other policies affecting the

responsibility for data elements.

·e4. Implementor of Record -- Data Integrity

For each data segment for which Ecology is the lOR, Region 10 agrees not to add

new data, change, or delete existing data in the Region 10 regional consolidated

data base without the consent of Ecology's RCRIS PO. The reverse is also true -

Ecology agrees not to add new data, change, or delete existing data for which

EPA is the lOR

Although lOR is assigned at the block level, there are certain basic lOR decisions

to be made that may logically require a set of blocks to be assigned to only one

lOR. For example, data submitted on a Notification Form may fall into separate

lOR blocks, but since only one Agency will receive and process the form, that

Agency should be the lOR for each of those associated blocks.

Ecology and Region 10 agree to the following basic lOR decisions, which are also

reflected in the assignment of lOR responsibilities as listed in the lOR Table that

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follows:

(a) Notification forms will be received and reviewed by Ecology and

forwarded to Region 10 for 10 number assignment and data entry. . .

(b)

(c)

(d)

(e)

Part A forms will be received and reviewed by Ecology and

forwarded to Region 10 for data entry.

Ecology and Region 10 have agreed on implementer-defined values

for the Contact Type data element.

Permitting unit groups will be jointly agreed upon by Region 10 and

.Ecology on a facility specific basis. After parallel operations begin,

Region 10 will be the lOR (lOR = Region 10) for joint permitting

authority. Upon demonstration that Ecology has appropriate data

collection in place to report joint permitting activities, Ecology will

be designated lOR for joint permitting.

Corrective action instruments, events, waste constituents, and

geographic areas will be designated by Region 10 in consultation

with Ecology (lOR = Region 10). Once Ecology is authorized to

administer the Hazardous and Solid Waste Amendments (HSWA),

Ecology will assume lOR responsibilities for corrective action

activities and instruments.

The lOR assignment table is as follows:

lORTABLE

IORBLOg RCJUS FILE

HANDLERm HANDLER 1

HANDLER 1 HANDLER 1 Noti1Ica1laD

HANDLER OWNIOP HANDLER 2 No1i&::atioD

Put A

HANDLER SIC CODE HANDLER 2 Put A

HANDLER PERM11' HANDLER 2 PartA .

HANDLER CONTACT (dependent on value In data element CONTACT TYPE)

Type N • Notilk:atal HANDLER 2 NoIifica1ioD

Type A· Part A Part A

Type R • BIennial Report Biennial Report

Type Eo F. 0. II. I.J Slate detiDed

Type E, L, M EPA detlDed

4

R

R

R

R

R

R

R

S

S

R

{)
JOBBLOCI IOUIaI

HANDLER SOURCE (dependent em nlue III data eIemIN SO~ OF INFODL\TlON)

Soume • N HANDLER 2 NodlIndoa

Soume • A Put A

Soume • R 8IeImW Report

Soume • E EPAEDcwIedge

Soume • S Stale 1mowtedoe

R

I

S

R

S

PERMrrl'INO UNIT CROUP R

PERMrrl'INO P£RMJT (dependent on nlue In data elemenl PERMrr A1JTHORJT'!)

Authority • E PEVENT EPAudbortry

Authority • s StaJe aathortly

Autbodty • J Joint aDthortty

PERMITI1NO EVENT (dependent on nlae In data eleaent EVENT RESPONSIBLE AOENC!)

Event RA • E PEVENT EPA pennlt actlon

Event RA • S Stale permit aetkm

CM & E EVALUATION. (dependent on nlue in data element EVALUATION RESP.AOENCY)

EnI. RA • E CEEVAL EPA IDspection

Enl. Il..A. • S Staie kwpec:"uan

Enl. Il..A. • X Ot'en:ight lnapecticn

Enl. Il..A. • C EPA CIODtnctor

Enl. Il..A. • B Stale contractor

CM & E VIOLATION (dependent on vaIue in data elemenl EVALUATION RESP.AGENCY)

Enl. RA • E CEVIOL EPA~n

Enl. Il..A. • S Stale Inspec:tion

Enl. RA • X Oversight iMpection

Enl. RA • C EPAcoatnctor

Enl. RA • B State contractor

CM & E ENFORCEMENT (dependent emnlue In data elementENFORCEMENT RESP.ACiENC'1')

Enl. RA • E CEENFOR EPA Dpection

Enl. RA • S Stale Inspec:ticm

Enl. RA • X Oversight inspection

R

S

R

R

S

R

S

R

R

S

R

S

R

R

S

R

S

R

CA.CONSTI'l'UENT CACONST

CA. Implementer agency

CA. 1a'rpIementer &gelIq'

R

R

CA.EVENT (dependent en nlue In data element EVENT RESPONSIBLE AGENC!)

£tent RA • E CAlNST CA.lmplementer acticM

£tent Il..A. • S CA.lmplementer ~na

£tent RA • J CA. Implementer ~na

£tent RA • 0 (otherJTcluntuy CA ~e inqXementec acdoaa

Ennt Il..A. • P (other/Ycluntary) CA EPA im;lementer actioM

CA. INSTRUMENT (dependent on value in data element INSTR~ RESP.AGENCY)

Inst Il..A. • E CAlNST CA.Pennil or Order

Inst Il..A. • S CA Permit or Order

Inst Il..A. • J CA.Pennil or Order

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R

S

R

S

R

R

S

R
IOBBttOCI ICRJS FJLB

PM OOMMJTMENTS (dependeN OQ nlue In daIa eMnwnt COMMITMENTTtPE)

Comm. Type • ORC PMOOMMJ'l' EPNStat. grant comm.

Comm. Type • ORP projecdcn

Comm. Type • M!I Multi-year Itrategy, Imp.

Comm. Type • JrnO Multi-year malegy, em.

Comm. Type • SPM SPMS

·5. Universe Calculations

Ecology and Region 10 also agree .that the RCRIS "authorization status"

element be set to 'W (No) resulting in the hierarchy by which universes

will be calculated to E.S-A-N. This means the views of EPA prevail over

the State's view, over Part A information, and over Notification data.

Although Region 10 is the lOR for Handler Status, Region 10 will discuss

changes to the TSD universe before making any changes to the data base.

This will be done at quarterly sites meetings or conference calls and the

change documented in a memo. A copy of this memo will be forwarded to

Ecology and the handler(s) files(s), as well as to data entry.

When Region 10 and Ecology mutually agree that the State has

appropriate data collection capabilities, the hierarchy will be set to

S-E-A-N.

R

R

R

R

R

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6. Dispute Resolution

Ecology and Region 10 agree that a dispute resolution procedure must be

formally established in order to expeditiously resolve any conflicts that may

arise between the two Agencies regarding the value/content of the data in

RCRIS. Therefore, Ecology and Region 10 agree to assume responsibility

for reviewing the exception reports generated during the merge process, as

well as any other tools that may be identified, in order to identify the

possible areas of dispute. If the non-lOR is in disagreement with the lOR,

then they will assume responsibility for initiating the resolution procedures.

Ecology and Region 10 agree that disputes should be resolved at staff level

whenever possible. Once elements in dispute have been identified, the PO

will contact his/her counterpart, either by telephone or in writing, within

five days, to discuss the data in question. If Ecology and Region 10 Project

Officers cannot resolve the dispute, then they will bring it to the attention

of their immediate supervisors,. Resolution will have been attempted for no

more than two weeks before this escalation occurs. If necessary, final

authority for dispute resolution will reside with the EPA Hazardous Waste

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Management Branch Chief and the Solid and Hazardous Waste Program

Manager.

Ecology and Region 10 agree that the maximum timeframe for resolution

of all disputes will not exceed 4S days. While the dispute is being resolved,

the lOR hierarchy established in the MOU will determine the official view

of the information.

Ecology and Region 10 agree to develop Information Management

Procedures. These procedures will at a minimum define the flow of data

from various program areas to data management staff for data entry in a

. timely manner; timeframes for data entry and upload to the merge data

base; data quality assurance and control procedures; and handling of

related documentation, including provisions for transmitting copies to the

co-implementer. These procedures must be developed and in place before

RCRlS is designated the official data base for data.

Ecology and Region 10 agree to adhere to these procedures. If Ecology

and Region 10 mutually determine that the procedures prove inadequate

for the ongoing operation of RCRIS, then Ecology and Region 10 agree to

revise the procedures.

Information Sharing

Ecology agrees to transfer all RCRIS data elements, including information

on facilities regulated only by the state, to the merged data base. Region

10 also agrees to transfer all RCRIS data into the merged data base. Both

agencies will therefore have access to the identical information after a

merge cycle is completed. The data will be transferred to the merge data

base once per month. '

8. Database Conversion and Initialization

Ecology bas agreed to initialize RCRIS from HWDMS data. Region 10

agrees to conduct and pay for the cost of the conversion. Ecology and

Region 10 will review the converted data base for accuracy and quality of

data. Post-conversion clean-up activities will be coordinated between the

two agencies as inaccuracies in the data are identified Data that does not

meet Ecology's high data quality standards will not be loaded into RCRIS.

9. Hardware/Software Maintenance

The Information Resource Management staff responsible for data

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processing for both Region 10 and Ecology will maintain close working

relationships. This will assure that data processing operations and

telecommunications functions, as required to support program operations, 0

are implemented. Region 10 will provide funds for updates of RCRIS

software as system requirements are modified Ecology is responsible for

obtaining and installing new versions of FOCUS and reprogramming their

RCRIS application software. These expenses are grant eligible,

10. EPA Oversight Role

Region 10 will continue to perform its oversight function as stipulated in

the annual SEA and operating grant agreements. Reports will be extracted

from RCRIS by Region 10 to evaluate Ecology's performance of the

delegated RCRA program activities. .

11. Amendments to MOV

Should there be significant changes in RCRA policy or a substantial

enhancement or modification to RCRIS, Region 10 and Ecology agree that

this MOU will be amended by letter to add provisions to ensure the timely

management of quality data in RCRIS.

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12. Grant Incorporation

This MOU is incorporated by reference as part of the FY 91 grant, and is

part of the Information Management commitments and milestones as

contained in the FY 91 RCRA Cooperative Agreement Work Plan.

13. Effective Date

This agreement is meant to provide the framework within which Ecology

and Region 10 intend to initialize and operate RCRIS. This agreement

does not waive any legal rights that either party has, nor does it provide

any rights to facilities or persons not a signatory. Once executed, this --

MOU will continue in effect unless modified by mutual consent of both

parties. However, this MOU is subject to re-negotiation based on revisions

to the RCRIS implementation process and national implementation

framework, revisions to relevant State or Federal guidance, regulations, or

statutes, or revisions to the State's RCRM-ISWA authorization status. The

MOU becomes effective on the signature date..

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SIGNATURES

United States

Environmental Protection Agency

; 1

Chuck Findley, Director

Hazardous Waste Division

/;;<f!r/

Oark

a&~ Gaulding

Assistant Regional Administrator

Policy and Management

pj'fJ

Washington State

Department of Ecology

~~.

Tom Eaton, Program Manager

Solid and Hazardous Waste Program

Date: 11/2-q {q 0

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