APPENDIX VII 

) 


RCRA DATA MANAGEMENT LETTER OF AGREEMENT 


BETWEEN 


IDAHO DEPARTMENT 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 Information System (RCRAInfo), which 

now includes Hazardous Waste Report data (from the former Biennial Reporting System). This 

document replaces the previous RCRIS Memorandum ofUnderstanding (MOU). 

RCRAInfo 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 information needed to support the implementation ofRCRA, as well as provides 

information needed by EPA Headquarters to support their functions. 

EPA Region 10 and Idaho DEQ equally share access to RCRAInfo. 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 RCRAInfo by Idaho DEQ. 

This document upholds the following basic principles: 

• 	 Serves as the official agreement between EPA Region 10 and Idaho DEQ by identifying 

the areas ofinformation management associated with maintaining RCRAInfo data; 

• 	 Clarifies RCRAInfo data management requirements and procedures; 

• 	 Improves partnering, information sharing and the quality ofRCRAInfo data; 

• 	 Provides a formal procedure for resolving disputes over the content ofthe data. 

General Agreements: EPA Region 10 and Idaho DEQ agree to share all data within the 

RCRAInfo handler, compliance/monitoring/enforcement, permitting, corrective action, and waste 

activity modules. The responsibility for entering hazardous waste data is that ofthe Agency 

performing the data collection. Data will be entered within the time frames specified for each 

module. The data that must be entered by EPA Region 10 and Idaho DEQ is the "Systemrequired" or "Nationally required" data as defined by the most current version ofthe RCRAInfo 

Data Element Dictionary (DED). 

Staffing: Idaho DEQ will appoint one person to be the primary data contact for RCRAInfo data 

management, including the national Hazardous Waste Report cycle. This person will function as 

the technical contact and State Data Administrator (SDA). The SDA will be responsible for 

communicating with EPA Region lOon issues related to RCRAInfo. In addition, the SDA will 

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be responsible for making sure Idaho DEQ users are trained, documentation is kept up-to-date, 

QAlQC is performed according to established time frames, all data is entered or sent to EPA 

Region lOin 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 staffshould work together to ensure that RCRAfufo data management is 

successful. The EPA Region 10 RCRAInfo Systems Administrator (RSA) will assist and support 

both staff when problem-solving and in interpreting RCRAfufo requirements. EPA Region 10 

and Idaho DEQ agree to consult with each other frequently about data decisions that are new or 

unusual and any decisions that affect the calculated universes. 

Data Ouality: 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 

QAlQC activities. These activities will include, but not be limited to the following: verification 

ofreal-time data with hard-copy files; review of permitting and corrective action reports for 

activity completeness; unresolved violation reviews and updates; and Idaho DEQ staff reviews of ) 

facilities as requested by EPA Region 10 staff. 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 RCRAInfo will be counted as completed. The responsibility for correcting 

data problems will be negotiated between the two Agencies with regard to efficiency and 

acceptability. 

Electronic Data Access: RCRAInfo User IDs will remain the same as those used in the RCRIS 

mainframe ifthe 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 Issuance: Idaho DEQ has primary responsibility for the Handler 

module, including the generation and issuance ofHazardous Waste ID numbers (ID numbers) 

accomplished by completing an uN"or "I" record. ID number issuance will occur within 10 days 

ofreceipt of a completed RCRA Subtitle C Site Identification Form [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 use an agreed-upon programmatic process to come to agreement on a RCRA 

handler status that is entered in the database. 

2 

·State-only· Hazardous Waste ID Numbers: In addition to being responsible for issuing ID 

numbers 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 RCRAInfo 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-notifiers it discovers into 

the RCRAInfo handler module as an "I" 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 federallyrecognized Indian reservation boundaries. However, Idaho 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 official list of existing ID number sites to be turned over to EPA for regulatory authority, 

Idaho DEQ will continue to process EPA ID number 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 Facility Nomenclature Standard. This will ensure that the data drawn from national 

systems to respond to EPA and Idaho DEQ staff reporting 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 RCRAInfo, the official universes will be those calculated by 

the model described in the RCRAInfo DED. 

Documentation: Idaho DEQ will maintain complete physical andlor electronic files on each 

handler issued a RCRA ID 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, State defined codes used in RCRAInfo, and data 

QAlQC activities with schedules and time lines. The documents will be resubmitted to EPA 

Region 10 when revisions occur to the originals. 

3 

ComplianceiMonitoring/Enforcement (CM&E): Idaho [)EQ will review its CM&E data 

annually or as needed to resolve site-specific data questions. Updates to the CM&E module of 

RCRAInfo will be entered within 30 days ofthe action taken. The State's unresolved violations 

will be reviewed quarterly by Idaho DEQ and all activities related to these unresolved violations 

updated. EPA Region 10 and Idaho 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 RCRAInfo 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 ofreceipt. All 

State activities related to the RCRAInfo PermittingiClosure module will be entered within 30 

days after they occur. Idaho DEQ will establish and maintain a process to assure that each pennit 

writer 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 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. Idaho DEQ will establish and maintain a process to assure that 

each eorrective 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 RCRAInfo Corrective Action reports 

will be used to assess and manage data 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 eopy or report menu selection. Both Agencies will ineorporate these reports 

into their regular data analysis. 

Annual and Biennial Reporting: Idaho DEQ will collect, proeess, 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 Generators. The Idaho Hazardous Waste Management Report is due 

to the Governor and Idaho Legislature by March 1. Federal biennial reports are due March 1 of 

every even-numbered year for the previous 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, 

formerly known as the BRS reporting cycle. 

Dispute 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 to the other Agency. 

EPA Region 10 and Idaho DEQ agree to resolve disputes at the stafflevel whenever possible. 

Once the elements of a dispute have been identified, the Agency identifying the items will 

contact the other Agency to discuss the data in question. Ifstaff cannot resolve the problem, it 

will be escalated to the Unit/Section management level for resolution. Ifit is determined that 

resolution cannot be reached at the first management levels of both Agencies, the problem will 

be escalated to the next level ofmanagement for a review/decision until it reaches the highest 

management level. Final authority for dispute resolution will rest with the EPA Director ofthe 

Office of Waste and Chemical Management and the Waste Management and Remediation 

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 lOin terms ofAuthorization, or substantial enhancement/modification to the 

database system, EPA Region 10 and Idaho DEQ agree that this document may be amended to 

add provisions that ensure the timely management ofquality data in RCRAInfo. This agreement 

does not affeet 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 RCRAInfo 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 ofAgreement. 

US Environmental Protection Agency Region 10 Idaho Department ofEnvironmental Quality 

Office of Waste & Chemicals Management Waste Management & Remediation 

RCRA Program HWMA Program 

7 

&I</CO~~- Brian Monson, Manager 


Reso 


Date Date 

RECEIVED 

JUN 	 232003 

O.E.O.STATEWASTE 

MANAGE,IENT &REMEDiATION DIVISION 5