RCRAInfo National Data System for RCRA Subtitle C Hazardous Waste Information

1. RCRAInfo National Data System for RCRA Subtitle C Hazardous Waste Information 2008 Exchange Network National Meeting April 29 � May 3, 2008 Nashville, TN

2. 2 RCRAInfo History/background RCRAInfo is EPA's comprehensive information system, providing access to data supporting the Resource Conservation and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments (HSWA) of 1984. RCRAInfo replaces the data recording and reporting abilities of the Resource Conservation and Recovery Information System (RCRIS) and the Biennial Reporting System (BRS). RCRAInfo: enables cradle-to-grave waste tracking data on regulated RCRA Subtitle C hazardous waste handlers characterizes facility status, regulated activities, permits, corrective action activities, and compliance histories captures detailed data on the generation of hazardous waste from large quantity generators and on waste management practices from treatment, storage, and disposal facilities.

3. 3 RCRAInfo Application RCRAInfo was designed and developed by a team of State and EPA representatives and was deployed in Sept 2000 and provided the following: a convenient user interface for program staff and managers. The system was and is coded and maintained by in-house EPA OSW personnel to control cost and maintain system knowledge and expertise. 90% of RCRAInfo costs are to cover Government FTE expenses. the ability to use commercial off-the-shelf software to do ad-hoc reporting directly from database tables anyone who can connect to the Internet can connect to RCRAInfo � no special software needed GUI interface, drop-down lists, and other "point-and-click" tools simplify viewing, entering, and retrieving RCRA data screens have a consistent look and feel across modules data business rules are enforced by the software through data entry edits, therefore, partial records are not allowed and data quality is improved data ownership: each record is "owned" exclusively by its data entry source, and this ownership is used to enforce security for later data editing enables data viewing and printing for program staff and management. Screens provide data presentation for online viewing of the data, often eliminating the need to print a report, but reports can be routed to a local laser printer in a graphical report format.

4. 4 Complexity of RCRAInfo RCRAInfo consists of 5 main modules: Handler: basic data necessary for tracking and monitoring a handler (facility name, address, contact information, lat/long, what facility is doing, etc.). Handler information is obtained from Notification and Part A forms submitted to the appropriate agency, including assignment of temporary and emergency IDs, and implementer defined submissions. Permitting, Closure, and Post-Closure: allows tracking facilities through the permitting process, facilities conducting closure and post-closure activities.� � Corrective Action: allows tracking the specific corrective action information needed to regulate facilities found to have hazardous waste releases. Includes the specific authority driving the corrective action activities such as permits or corrective action orders, the areas affected by the release, and the events that track the progress of the corrective action.

5. 5 Complexity of RCRAInfo (continued) Compliance Monitoring and Enforcement (CM&E): basic data necessary for determining a handler's level of compliance with regulatory requirements (including: inspections/evaluations, violations, and enforcement actions). Waste Activity Monitoring (WAR): information about the generation, management, and final disposition of hazardous waste (including: the quantities, nature, and disposition of generated hazardous waste). The WAR module contains the Biennial Report data and has tables which correspond to the forms (the Site Identification, GM, and WR forms). RCRAInfo also contains the following supporting modules: National and Implementer Reports: �canned� reports plus BARRT; a Basic RCRAInfo Reporting Tool to help non-programmers build their own ad-hoc reports. Utilities: Change Password, User Preferences, Groups of IDs, Status Reports System Administration (i.e.: look-up take maintenance) USITS (User Support and Issue Tracking System) utility allows users to submit, view, and track all user issues for the RCRAInfo application. News Alerts and General Information which contains documentation on PAAs, software releases, Change Management process, and conference information (presentations for all RCRAInfo National Conferences).

6. 6 Complexity of RCRAInfo (continued) So how big is RCRAInfo? Total number of RCRAInfo tables 596 Total number of RCRAInfo data elements 8,191 Total number of RCRAInfo records 139,286,791 There are currently 2,185 RCRAInfo users nationally. HQ (OSW and OECA) have read only access to RCRAInfo. RCRAInfo contains data entered by 67 government partners: all 10 Regions, all 50 States, 5 territories (Guam, Porto Rico, the Virgin Islands, Trust Territories, & American Samoa), the District of Columbia, and one Tribe (Navaho Nation). In RCRAInfo, we refer to all these government partners as states. RCRAInfo does not allow direct public access, rather data is transferred to the Agency's EnviroFacts system, NTIS, and an ftp site for access by the public and the regulated community.

7. 7 RCRAInfo Design RCRAInfo was designed and developed by a team of State and EPA representatives and was deployed in Sept 2000, since then all revisions have utilized this same State/EPA partnership model. Program Area Analyses (PAAs) were conducted to look at all modules. The PAA (State/EPA programmatic representatives) looked at that area of business (Handler, Permitting, etc) to ensure the right data was being collected. Their recommendations were then sent for full National Review and comment, revisions were made based on these comments and a Management Board (State/EPA) reviewed and gave final approval. A Design Team (State/EPA technical representatives) was formed to propose technical implementation for each PAAs recommended change, with their technical specifications being sent out for full National Review and comment and revised based on comments received. Only then were these changes coded in RCRAInfo and placed in pre-production for testing by the full RCRAInfo user community. After successful testing was completed, the modified version was moved to production. PAAs were completed for the following releases: V2 Sept 2002: Universe Identification & Waste Activity Monitoring (UID/WAM) V3 June 6, 2006: Handler Monitoring and Assistance (HMA) V4 will be Dec 2008: Permitting and Corrective Action (PCA) PAA, which includes two new modules (GIS & Financial Assurance) has been completed, Design has been completed, we are in the coding phase and expect to release to the user community for testing in end of Sept 2008 with a final release after the National RCRAInfo Conference, December 2008.

8. 8 How are changes made after V4 Once V4 is released, all the PAAs will have been completed - meaning all modules in RCRAInfo will have been analyzed by a team of State and EPA program experts, within these last 8 years, thereby ensuring that the data needed to manage that program area is the correct data needed by both State and EPA programs. Having completed this, RCRAInfo will then go into O&M operations. Changes will be submitted by the user community via a module in RCRAInfo (USITS). Changes can be for enhancements; modifications to existing software or edits; bugs; new functionality; requests for new reports; or anything else which the user community may need or desire. All requests, except bugs (which will be corrected as soon after discovery as possible) will be sent through the Change Management Process (CMP). Change Management Process - The CMP is made up of State/EPA representatives (programmatic & technical). CMP has a Coordination Group (CG) which handles day-to-day operations and technical experts for each of the modules in RCRAInfo. Once the CG has approved a recommendation, it will be sent out for full National Review and comment, based on the comments, changes may be made and the recommendation will then be presented to the CMP Management Board to grant final approval of recommendations. All minutes from CMP meetings and issues reviewed are posted in RCRAInfo under Documentation for all users to view. See list of current State and EPA representatives on CMP attached to the end of this PowerPoint presentation.

9. 9 Exchange Network and RCRAInfo Since some States have their own systems which contain RCRA Subtitle C data. OSW partnered with OEI to provide States the ability to send their data to RCRAInfo in one of 3 ways: - Node-to-Node connection for an XML submission - CDX web XML submission - CDX flat file submission. These States are called translators in RCRAInfo, since they translate their state data into RCRAInfo. OSW committed, even before RCRAInfo was developed, to ensure that any change to the structure or any other change affecting how a translator state sends data to RCRAInfo are only done yearly and that there would be a 6-month notice to States before these type of changes are implemented. OSW publishes a Translator Guide containing the file specifications for each release. This Translator Guide has the file definitions and all edit rules which will be run on the file. This Translator Guide is published 6 months before the changes go into effect, so as to provide States an opportunity to make any necessary changes on their end.

10. 10 Exchange Network and RCRAInfo (continued) Version 4 - Will require changes on the part of translator States. V4 is scheduled for release December 2008. The V4 Translator Guide was published February 2008. As development continues, additional changes may need to be made to this Translator Guide and will be documented in a Translator Guide Change Log. Both the Translator Guide and the Change Log are posted in RCRAInfo under Documentation. States should be using this Translator Guide to begin the investigation and implementation of any changes which may be needed to ensure their continued ability to translate current data. States who have their own system for GIS and Financial Assurance data and desire to translate this data, instead of entering it into RCRAInfo directly, should be using this Translator Guide to make any necessary modifications to enable them to translation these data. Next week OSW will be sending out a list of differences affecting translation of Handler and CME data between V3 and V4 to make it easier for translators to identify changes to these two modules. Translators will need to thoughouly review Permitting and Corrective Action.

11. 11 Does Every State Use RCRAInfo? No. There are currently 11 states translating data to production RCRAInfo and 4 others who are testing. This makes a total of 18 different states sending data (or testing their send process) to 3 modules (Handler, CM&E, and Permitting). No one is sending or testing sending data to the Corrective Action module. Handler (11 in production and 3 testing) CDX Flat file (5 in production and 1 testing) AR (only periodically when large qty to update) DE TESTING ONLY FL MD TESTING ONLY MI Apr 08 failed (but has had previous successes) OH (for very special circumstances for batch loads, state finds it easier to do direct data entry) OR TX WA CDX xml (1 in production ) MS node-to-node (3 in production and 1 testing) MA node-to-node Mar 08 failed (but has had previous successes) NH PA AZ TESTING ONLY

12. 12 Does Every State Use RCRAInfo? (continued) Permitting (0 in production and 1 testing) CDX Flat file (1 testing) CA CDX xml (none) None node-to-node (1 testing) NJ TESTING ONLY CME (8 in production and 0 testing) CDX Flat file (6 in production and 1 testing) CO flat (inspection only) FL MI Dec 07 failed (had previous successes) MN OR TX CA CDX xml (none) None node-to-node (1 in production) PA

13. 13 Does Every State Use RCRAInfo? (continued) Currently RCRAInfo has the following: 14 states translating data to RCRAInfo 4 states testing their translation process ------ 18 or 75 % of total possible universe We know of 7 additional states who either have states systems or who are thinking of developing a state system for RCRA Subtitle C data and are then hoping to become translators (DE, SC, TN, IL, WI, MO, & NE). This would mean a potential universe of 24 states who could translate information into RCRAInfo at sometime in the future. 2 additional states have state systems but have decided against becoming translators for RCRA data (IN and NC).

14. 14 Who Helps Translators? Setting Privileges: When a State becomes a Translator they must work with their State data system staff, OSW (RCRAInfo staff), and OEI (Exchange Network/CDX staff) to ensure the appropriate privileges are set-up. Establishing Formats: Once privileges are set-up, they again must work with their State systems staff to ensure that the State is sending data in the agreed upon format and all edit check �rules� have been met. These are found in the Translator Guide and can be used as-is for flat file submissions. XML submissions use the same information from the Translator Guide but also must adhere to the appropriate schema format instead of flat file format. Data Transmission: When a State is ready to begin testing their data, they will send their data file to the Exchange Network/CDX for RCRAInfo pre-production. Once a file has been sent, sit is the responsibility of the State staff to verify the success or failure of the submission. OEI and OSW have tools in place to assist States with this process. OEI will e-mail the State once a submission either fails or successfully completed. If the submission does not successfully exit CDX the State should contact the CDX Helpdesk for assistance in correcting the problem. If the submission successfully completed CDX, the State must check the point and click Status log in RCRAInfo to verify if the submission was successful. If the RCRAInfo Status Log reports that submission as successful. The process is completed.

15. 15 Who Helps Translators? (continued) If the RCRAInfo Status Log contains errors the errors listed correspond, by number, to the edit numbers listed in the Translator Guide enabling the State to determine why the error occurred and what needs to be changed. If the State needs assistance with understanding the errors contained in the Status Log RCRAInfo�s Idali Gotay (703-308-0512 or gotay.idali@epa.gov) will be happy to help. Note: Eric Schwarz is no longer the contact person for translation, please contact Idali. HQ recognizes that this sounds easy, but may be difficult and could involve changes to State data systems or State�s business practices. But these changes have been identified as necessary by both State and EPA to manage their RCRA Subtitle C program and all have been made with review and approval of the RCRAInfo community, including translator States. These changes were also published 6 months, before they were implemented. During this time OEI (CDX Helpdesk staff), OSW (RCRAInfo staff) and the State should all be communicating and sharing information to help facilitate a successful translation. Once the State has had a successful translation to RCRAInfo the process is completed and should run smoothly unless one of the three parties OEI (Exchange Network/CDX), OSW (RCRAInfo via Translation Guide modifications), the State data system, or the State extract program change something. As mentioned earlier, OSW will not make changes without notification of the user community. Changes affecting translators will not be made more that once per year. A modification will be made to the Translator Guide 6 months prior to implementation of the change. OSW will be participating in the monthly RCRA IPT data calls beginning in May and we will begin sending relevant news to OEI to post as an Exchange Network News Alert.

16. 16 How Are XML Files Currently Processed? How Will This Change With V4? For all versions before V4, OSW created draft schemas which were sent to OEI for approval and submission to ECOS. Once a schema is approved OEI coded a converter to accept the XML file and �convert� it to a flat file format so RCRAInfo could process it. In an effort to help simply this part of the translation process, RCRAInfo will implement the ability to directly process XML files for Permitting, Corrective Action, GIS, and Financial Assurance data with V4. This will eliminate the need for the converter step.

17. 17 V4 Schedule V4 High Level design with Structure Charts posted in RCRAInfo Jan 18, 2008 Translator Guide posted in RCRAInfo Jan 18, 2008 Begin Design Team Testing of V4 software Aug 1, 2008 Design Team meeting (testing review/conference preparation) Aug 19-21, 2008 User Community testing of V4 software begins Sept 22, 2008 National RCRAInfo User Conference (DC at the Gaylor National Harbor) Dec 2-5, 2008 RCRAInfo Production shutdown after conference for conversion of data and moving of software application RCRAInfo will be unavailable Dec 5-12, 2008 RCRAInfo Version 4 goes live Dec 15, 2008

18. 18 What�s Coming After V4? Once V4 is out and States are successfully translating data, OSW will begin to re-code the Handler and CM&E translation process to also be able to accept XML files directly without the need for the OEI converter program. This re-coding will require no changes to translators, it will only replace the use of the behind the scenes converter. (Schedule will depend upon resource availability following the V4 release). Outbound Flows: OSW is aware that there are some States that would like the ability of an �outbound� flow added to RCRAInfo. OSW recognizes the need to share data from RCRAInfo and upload it to State systems and has provided data extracts for any State requesting them. After OSW has made the modifications to enable all modules to translate XML files directly without the need for converters, we will work with States and OEI on outbound flows.

19. 19 Change Management Representatives Coordination Group States: EPA: ID (Chair) Region 1 OH Region 4 NC Region 5 TX HQ OSW (Chair) State Vacancy HQ OECA Site Identification Group States: EPA: ID Region 1 OH Region 9 KS HQ OSW IL Permit/Closure Group States: EPA: ID Region 1 MO Region 8 CO HQ OSW NC Corrective Action Group States: EPA: AR Region 4 MO HQ OECA State Vacancy HQ OSW

20. 20 Change Management Representatives (continued) Compliance/Monitoring/Enforcement Group States: EPA: IL Region 1 ME HQ OECA WA Waste Activity Group States: EPA: IL Region 1 TX HQ OECA FL HQ OSW CA Translation Group States: EPA: MI Region 1 CA HQ OEI MA HQ OSW Management Board States: EPA: AL Region 10 MD HQ OECA OH HQ OSW

21. 21 If you have any questions about this presentation, please feel free to contact: goodwin.debbie@epa.gov