# e- - '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/?dIlta:
3-6-2 

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# e 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 ofResource Conservation and Recovery Act Information System (RCRIS). This includes the Implementor ofRecord (lOR) designation and the standard protocols for system operation. The purpose ofthe 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 ofdata 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 10and EPA Headquarters for their oversight functions. As a result of co-imp1ementation of the RCRA program. both Ecology and Region 10 

### willmaintain separate RCRIS implementer data bases. When merging the information from these two data bases, it is necessary to ensure the integrity ofthe 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 atboth 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 OFAGREEMENT 1. 

## EPNState Cooperation in SystemDevelopment/Maintenance Consistentwith 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

### bequickly communicated and followed by additional guidance, ifnecessary. Through the State EPA

. Agreement (SEA) workplan, funding for staffing, operating costs, and training for Ecology will be part ofthe yearly**gr~** 

# c

# • 2 Data Entry and Quality Ecology

### isconsidered a "Full RCRIS User" because RCRIS will be 

### their principle hazardous waste information system. 

### Asa full RCRJS user, they willelectronically 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 oversightRCRIS data. 

## 3. Data Management Responsibilities Ecology willappoint a RCRIS Project Officer (PO) who willmeet 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 workingrelationship 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 Ecologywill 

### appoint a Data Base 

### Administrator (DBA) to implement the details of this agreement DBA's 

### will work with the day-to-day management issuesoutlined in this 

### MOU. They will

### inform the PO ofchanges in the data dictionary (data elements and definitions), data handling protocols, lOR basic principles, merging ofstate and federal RCRIS data bases, changes to data base records, qualityassurance/quality control ofthe data, distribution ofupgrades and enhancements of the RCRIS software, and other policies affecting the responsibility for data elements.



# ·e4. Implementor ofRecord

--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'sRCRIS PO. The reverse is 

### also true - Ecology agrees not to add new data, change, or delete existing data for which EPA is the lOR AlthoughlOR is assigned at the block level, there are certain basic lOR decisions to be 

### made that may logically require a set ofblocks 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 ofthose associated blocks. Ecology and Region 10agree to the following

### basic lOR decisions, which are also reflected in the assignment oflOR responsibilities as listed in the lOR Table that 

# 3follows: (a) Notification forms will be received and reviewed by Ecology and forwarded to Region 

### 10for 10 number assignment and data entry.

. . 

### (b) (c) 

### (d)

(e) PartA forms willbe received and reviewed by Ecology and forwarded to Region 

### 10for data entry. Ecology and Region 

### 10have agreed on implementer-defined values for the ContactType data element. Permitting unit groups will be jointly agreed upon by Region 

### 10and

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

Region 

### 10will be the lOR (lOR 

### = Region 

### 10)forjoint permitting authority. Upon demonstration that Ecology has appropriate data collection in place to reportjoint permitting activities, Ecology will be designated lOR forjoint permitting. Corrective action instruments, events, waste constituents, and geographic areas will

### be designated by Region 

### 10in 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 PutA 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 PartA Type R • BIennial Report Biennial Report Type Eo F.0. II. I.J Slate detiDed Type E, L, M EPAdetlDed 

# 4 R R R
R R
R R S S R 

# {)

### JOBBLOCI IOUIaI HANDLER SOURCE (dependent emnlue III dataeIemIN**SO~** OF INFODL\TlON) Soume • N HANDLER2 NodlIndoa Soume • A PutA Soume • R 8IeImWReport 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!) EventRA • E PEVENT EPApennlt actlon EventRA • S Stale permit aetkm CM & E EVALUATION. (dependent on nlue in data element EVALUATION RESP.AOENCY) EnI. RA • E CEEVAL EPAIDspection Enl. Il..A. • S Staie kwpec:"uan Enl. Il..A. • X Ot'en:ight lnapecticn Enl. Il..A. • C EPACIODtnctor Enl. Il..A. • B Stale contractor CM & EVIOLATION (dependent on vaIue in dataelemenlEVALUATION 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 Statecontractor CM & EENFORCEMENT (dependentemnlue In data elementENFORCEMENT RESP.ACiENC'1') Enl. RA • E CEENFOR EPADpection 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 (dependenten nlue In dataelementEVENT RESPONSIBLE AGENC!) £tent RA • E CAlNST CA.lmplementeracticM £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 EPAim;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 orOrder Inst Il..A. • J CA.Pennil or Order



# 5 R S R S R

R S RIOBBttOCI ICRJSFJLB 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-yearmalegy, em. Comm. Type • SPM SPMS 

## ·5. Universe Calculations Ecology and Region 10 also agree

.that the RCRIS "authorization status" elementbe set to 'W (No) resulting in the hierarchy by which universes will be

### calculated to 

### E.S-A-N. This means the viewsofEPAprevail over the State's view, over Part A information, and overNotification 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 disputeresolution procedure must be formally established in order to expeditiously resolve any conflictsthat 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 othertools that may be identified, in order to identify the possible areas of dispute. If

### the non-lOR isin disagreementwith the lOR, then theywill assume responsibility for initiating the resolution procedures. Ecology and Region 10 agree that disputes should be 

### resolved at stafflevel whenever possible. Once elements in dispute have been identified, the PO will

### contact his/hercounterpart, either bytelephone or in writing, within five days, to discuss the data in question. If

### Ecology and Region 10Project Officers cannot resolve the dispute, then they will bring it to the attention of their immediate supervisors,. 

### Resolutionwill 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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# o

o

# • 7. Management Branch Chiefand the Solid and Hazardous Waste Program Manager. Ecology and Region 10 agree that the maximum timeframe for resolution of all disputes will not exceed 

### 4Sdays. While the dispute 

### isbeing resolved, the lOR hierarchy established in the MOU willdetermine the official view of the information. Ecology and Region 10 agree to develop Information Management Procedures. These procedures will at a minimum define the flowofdata from various program areas to data management stafffor 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 ongoingoperation ofRCRIS, then Ecology and Region 10 agree to revise the procedures. 

## Information Sharing Ecology agrees to transfer all RCRIS dataelements, including information on facilitiesregulated only by the state, to the merged database. 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 iscompleted. 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 10will 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 staffresponsible for data 

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### processing for both Region 10 and Ecology 

### willmaintain close working relationships. This 

### willassure that data processing operations and telecommunications functions, as required to support program operations, 

# 0
are implemented. Region 10

### will provide funds for updates ofRCRIS software as system requirements are modified Ecology is responsible for obtaining and installing new versions ofFOCUS 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 

### willbe 

### extracted from RCRIS by Region 10 to evaluate Ecology's performance 

### ofthe 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 byletter to add provisions to ensure the timely management of quality data inRCRIS.

I

I 

# r-----

I 

## 12. Grant Incorporation This 

### MOU is incorporated byreference as part ofthe FY 91 grant, and is part ofthe 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 initializeand 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 ofboth parties. However, this MOU issubject 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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# -0

## SIGNATURES United States Environmental Protection Agency ; 1 

### Chuck Findley, Director Hazardous Waste Division 

# /;;<f!r/

# a&~ OarkGaulding Assistant Regional Administrator Policy and Management 

# pj'fJ WashingtonState Department ofEcology

# ~~. Tom Eaton, Program Manager Solid

### andHazardous Waste Program Date: 

### 11/2-q

# {q0



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