# APPENDIX 

# VII

# ) RCRA DATA MANAGEMENT LETTER OFAGREEMENT BETWEEN IDAHO DEPARTMENT OFENVIRONMENTAL QUALITY

WASTE MANAGEMENT & 

### REMEDIATION DIVISION AND US EPAREGION 10 OFFICE OFWASTE & 

### 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 RecoveryAct (RCRA) Program. Thedatareferred 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 ofdata 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 byEPA Headquarters to support their functions.

EPA Region 10 and Idaho DEQ equally share access to RCRAInfo. There is no "Implementerof Record". EPA Region 10 and Idaho DEQ users with edit access are ableto change any data, except where agreed upon within this document. EPA Region 10 will not change handler data, sincehandler data is entered directly into RCRAInfo byIdaho DEQ.
This document upholds the following basic principles:

• Serves as the official agreement between EPA Region 10 and Idaho DEQ byidentifying 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 overthe 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 activitymodules. The responsibility for entering hazardous waste data is that ofthe Agency performing the data collection. Datawill be entered within the time frames specified for each module. The datathat must be entered byEPA Region 10 and Idaho DEQis the "Systemrequired" or "Nationallyrequired" data as defined by the most current version ofthe RCRAInfo Data Element Dictionary (DED). Staffing: Idaho DEQ will appoint one person to be the primarydata contact for RCRAInfo data management, including the national Hazardous Waste Report cycle. Thisperson will function as the technical contact and State Data Administrator (SDA). The SDA will beresponsible for communicating with EPA Region lOon issues related to RCRAInfo. In addition, the SDA will

11111111111111111111111I1I1111I111I1 

### 10264 I :OWRPberesponsible 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 providedto State Managers on data-related policyissues. Regional Role: EPA Region 10 will assist Idaho DEQinmaintaining the national database, provide assistance with access to Idaho DEQusers, develop/share agreed-upon reports, and conduct data oversight duties including the development and negotiation ofpoliciesrelated 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 entryand 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 staffwhen problem-solving and in interpreting RCRAfufo requirements. EPA Region 10 and Idaho DEQ agree to consult with each other frequently about data decisions that arenew 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 "NationallyRequired" data and byconductingregular 

### QAlQC activities. These activities will include, but not be limited to the following: verification ofreal-time data withhard-copy files; review ofpermitting and corrective action reports for activity completeness; unresolved violationreviews and updates; and Idaho DEQ staffreviews of ) facilities as requested byEPA 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 datausage. Only activities entered into RCRAInfo will becounted as completed. The responsibility for correcting data problems will be negotiated between the two Agencies withregard to efficiencyand acceptability.
Electronic Data Access: RCRAInfo UserIDs will remain the same asthose used intheRCRIS 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 maybe required to access the secure site with a compatible version ofInternet Browser software.

RCRA Identification Number Issuance: Idaho DEQhas primaryresponsibility for the Handler module, including the generation and issuance ofHazardous Waste ID numbers (ID numbers) accomplished bycompleting an uN"or "I" record. ID number issuance will occurwithin 10 days ofreceipt ofa completed RCRA Subtitle C Site Identification Form [8700-12] or State equivalent form. Idaho DEQwill issue new ID numbers, update, inactivate, reactivate, and verify existing ID numbers for all regulated handlers. When necessary, EPA Region 10and 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·HazardousWaste 

### ID Numbers: In addition to being responsible for issuing ID numbers to RCRAregulated handlers, Idaho DEQ may use the database to track handlers who
areregulated under Idaho's ownhazardous waste rules as long as the associated ID numbers begin withthe State's ownpostal code. "State-only" handlers in RCRAInfo mustbe readily discemable as being tracked for Statepurposes 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 handlermodule 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 withinthe federallyrecognized Indian reservation boundaries. However, Idaho currentlyhas a number ofsites that would appear to be within those boundaries that have notbeenpreviously designated as tribal based on the land and/or ownertype. Until such time as Idaho and EPA Region 10 can determine
an official list ofexisting ID number sites to be turned over to EPA for regulatory authority, Idaho DEQ will continue to process EPAID numberrequests as usual (at the request ofEPA Region 10).
Nomenclature: The Idaho DEQ site naming process willbe consistent withEPA's standard nomenclature policies as established inthe FacilityIndex System (FINDS) and EPA Region 10 Federal FacilityNomenclature 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 easyto pull.
TSD Universe Calculations: Because ofthe Government PerformanceResults Act (GPRA) implications and RCRAlnfo Universe calculations, both Agencies will consult with one another before making any changes to the TSD universe. This canbe done at quarterlymeetings, on conference calls, byofficial mail, or anyagreement documented to the otherAgency and placed into the handler's physical file. In RCRAInfo, the official universes will bethose calculatedby the model described in the RCRAInfo DED.
Documentation: Idaho DEQ will maintain complete physical andlor electronic files on each handlerissued aRCRA ID number. Copies ofall forms ordocuments submitted to Idaho DEQ that change handler site identification information, especiallyname and status changes, will be sent to EPA Region 10 monthly.
Idaho DEQ will document and share its datamanagement practices with EPA Region 10. These documents should contain, but are not limited to, Idaho DEQ's Standard OperatingProcedures (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 occurto the originals.

3ComplianceiMonitoring/Enforcement(CM&E): Idaho [)EQwill 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 30days ofthe action taken. The State's unresolved violations will bereviewed quarterly byIdaho 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.

EPARegion 10 and Idaho DEQ willjointlydecide 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 Agencywill make the reports available to the otherAgency quarterlyviahardcopy orreport menu selection. Both Agencies will incorporate these reports into their regular data analysis. Permitting/Closure: Datareceived on Hazardous WastePermit Information (8700-23 PartA) forms will beprocessed and entered into RCRAInfo by Idaho DEQ no more than 30 days after receipt. Where the State does not have regulatory authority, Idaho DEQwill send the Part A information to EPARegion 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 aftertheyoccur. 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 quarterlybasis and submit revisions to the SDA for data input.

EPA Region 10 and Idaho DEQ willjointlydecide whichRCRAInfo Permitting reports will be used to assess and manage data within the Permitting module. WhicheverAgency's reports are selected, that Agencywill make the reports available to the other Agencyquarterly via hardcopy
orreport menu selection. Both Agencies will incorporate these reports into their regulardata analysis.
Corrective Action: All Stateactivities related to the CorrectiveActionModule willbe 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 quarterlybasis and submit revisions to the SDA for data input.

EPA Region 10 and Idaho DEQwilljointlydecide which RCRAInfo Corrective Action reports will beused 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 otherAgency quarterlyvia hard eopyorreport menu selection. Both Agencies will ineorporate thesereports into theirregular 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 generatorreports are due every January 31 for the previous reporting year by Large and Small Quantity Generators. The Idaho Hazardous WasteManagement Report is due to the Governor and Idaho Legislature byMarch 1. Federal biennial reports are due March 1of every even-numbered year for the previous odd-numberedreporting year by Large Quantity Generators and Treatment, Storage, Disposal Facilities. Biennial report data will be on-time and

4) free oferrors prior to transmittal to EPA Region 10 for the national Hazardous Waste Report, formerly known as the BRS reporting cycle. Dispute Resolution: EPARegion 10 and Idaho DEQ agree to follow the procedure detailed below to resolve disputes. Wheneverdata problems occur, the Agency identifying the problem will be responsible for providing all pertinent data to the otherAgency.

EPA Region 10 and Idaho DEQ agree to resolve disputes at the stafflevel wheneverpossible. Once the elements ofa dispute have been identified, the Agency identifying the items will contact the other Agency to discuss the data in question. Ifstaffcannot resolve the problem, it will be escalated to the Unit/Section management level for resolution. 

### Ifit is determined that resolution cannotbe reached at the first management levels ofboth 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 ofWaste and Chemical Management and the WasteManagement and Remediation Division Administratorwith 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 EPARegion lOin terms ofAuthorization, or substantial enhancement/modification to the database system, EPARegion 10 and Idaho DEQ agree that this document may be amended to add provisions that ensure the timelymanagement ofquality data in RCRAInfo. This agreement does not affeet the legal rights that eitherpartyhas, nor does it provide anyrights to non-signing facilities orpersons. Once signed, this document will continueto be in effect until modified by mutual consent. Signatures: The individuals signingbelow agree to ensurethat RCRAInfo datamanagement is properly administered by EPA Region 

### 10 and Idaho DEQ. Any issues not covered bythis agreement will default to the RCRA Program MemorandumofAgreement.
US Environmental Protection Agency Region 10 Idaho Department ofEnvironmental Quality Office ofWaste & Chemicals Management Waste Management & Remediation RCRAProgram HWMA Program 

# 7

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

Date Date 

### RECEIVED



## JUN 232003

O.E.O.STATEWASTE MANAGE,IENT& REMEDiATIONDIVISION 

### 5