vvEPA
Xlnited States
Environmental Protection
Agency
Solid Waste ,and,
Emergency Response
(5305W)
EPA530-R-96-050
November 1996
The Hazardous Waste Program
Information Strategy Plan
aste
Inf
ormation
Needs
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION 1-1
1.1 BACKGROUND 1-1
1.2 DISCUSSION 1-2
1.3 ORGANIZATION OF THE REPORT .1-4
2.0 THE EPA HAZARDOUS WASTE PROGRAM ASSESSMENT 2-1
2.1 KEY QUESTIONS 2-1
2.2 KEY FINDINGS 2-1
2.2.1 Organization 2-1
2.2.2 Program Direction 2-2
2.2.3 Information Management Direction 2-2
2.3 DISCUSSION 2-3
2.3.1 EPA Hazardous Waste Program Organizations and Functions .... 2-5
2.3.2 Senior Management View of the EPA Hazardous Waste Program . 2-5
2.3.3 Strategies of the EPA Hazardous Waste Program 2-12
3.0 IDENTIFICATION OF EPA HAZARDOUS WASTE PROGRAM AREAS AND
INFORMATION NEEDS 3-1
3.1 KEY QUESTIONS 3-1
3.2 KEY FINDINGS 3-1
3.3 DISCUSSION 3-2
3.3.1 Key Program Activities 3-3
3.3.2 High Level Categories of Information Needs 3-5
3.3.3 Identification of Program Areas 3-8
4.0 EPA HAZARDOUS WASTE PROGRAM CURRENT SYSTEMS
ASSESSMENT 4-1
4.1 KEY QUESTIONS 4-1
4.2 KEY FINDINGS 4-1
4.3 DISCUSSION 4-2
4.4 CURRENT SOURCES OF INFORMATION 4-4
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CONTENTS (continued)
5.0 POTENTIAL TECHNOLOGIES AND EVALUATION CONSIDERATIONS . . 5-1
5.1 KEY QUESTIONS 5-1
5.2 KEYFINDINGS 5-1
5.3 DISCUSSION 5-2
5.3.1 Potential Technologies 5-2
5.3.2 Evaluation Considerations 5-7
6.0 PROGRAM AREA PRIORITIZATION AND RECOMMENDATIONS 6-1
6.1 KEY QUESTIONS 6-1
6.2 KEYFINDINGS 6-2
6.3 DISCUSSION 6-2
6.3.1 Overview of the Program Area Prioritization Based on Strategic
Importance and Level of Current Systems Support 6-3
6.3.2 Detailed Analyses of Priority Determinations for the Seven Program
Areas 6-5
6.3.3 Evaluation of Program Areas and Identification of Short-Term
Projects in Light of Internal and External Factors Influencing the
RCRA Program 6-17
7.0 TRANSITION PLAN 7-1
7.1 KEY QUESTIONS 7-1
7.2 KEYFINDINGS 7-2
7.3 DISCUSSION 7-3
7.3.1 Implementation Process 7-3
7.3.2 PAA Methodology 7-6
7.3.3 Proposed Projects 7-8
7.3.4 Issues to be Addressed by EPA and States 7-14
EXHIBITS
Exhibit 2-1. Five Steps in EPA's Hazardous Waste Program Assessment 2-4
Exhibit 2-2. Roles of Divisions within the Office of Solid 2-6
Exhibit 2-3. Roles of the Offices within the Office of Enforcement and Compliance
Assurance 2-7
Exhibit 2-4. RCRA-Related Roles within EPA Regional Offices (e.g., Hazardous
Waste Divisions 2-8
Exhibit 2-5. Coordination between GPRA and RCRA Strategic Planning 2-9
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EXHIBITS (continued)
Exhibit 2-6. EPA Program Goals and Strategies as Identified by Program Management
and Staff in 1995 Facilitated Sessions for the Purposes of Identifying
Information Needs 2-13
Exhibit 3-1. Key Activities and Sub-Activities of the EPA Hazardous Waste Program Used to
Identify Program Areas 3-4
Exhibit 3-2. Overview of the EPA Hazardous Waste Program Strategic Information Needs
Grouped into Eight High-Level Categories (numbers represent sub-category
denominations used in this assessment) . 3-6
Exhibit 3-3. Overview of the EPA Hazardous Waste Program Areas 3-10
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous
Waste Program 4-6
Exhibit 4-2. Some Sources for RCRIS and BRS Data 4-14
Exhibit 6-1. Prioritization of the EPA Hazardous Waste Program Areas 6-4
Exhibit 6-2. Overview of External and Internal Influences Affecting Information
Management 6-19
Exhibit 6-3. List of Short-Term Projects to Support the EPA Hazardous Waste Program 6-22
Exhibit 7-1. Preliminary Estimates of Resources, Schedule, and Outputs/Outcomes of
Recommended PAAs 7-11
Exhibit 7-2. Preliminary Estimates of Resources, Schedule, and Outputs/Outcomes of
Recommended Short-term Projects 7-13
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
APPENDIX G
APPENDIX H
APPENDIX I
APPENDIX J
APPENDIX K
- OSW Strategic Plan
- Description of the Information Engineering Methodology (IBM)
- List of Executive Interviewees
- WIN & Agency Initiatives
- Attendees List for September 1995 Meeting
- RCRA Program Goals and Strategies
- Information Needs Descriptions
- Description of the IBM Process Used to Identify Program Areas for the EPA
Hazardous Waste Program
- Curent Systems Assessment Analysis
• Description of the EPA Hazardous Waste Program Area Prioritization
- Briefing on the RCRIS Lessons Learned Project
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Objectives of the WIN Initiative
Reassess the information and data
quality needs of all stakeholders in
the RCRA hazardous waste
program
Provide improved access to
required information
Reduce the burden of data
generation and collection
Identify the appropriate information
technologies to provide more useful
and accessible data to all users.
EXECUTIVE SUMMARY
Reinvention of information management in
the Environmental Protection Agency (EPA)
hazardous waste program began in 1994,
when the Office of Solid Waste (OSW)
revised its strategic plan, and identified a
series of information management objectives
as part of its Five-Year Strategy. The Waste
Information Needs (WIN) initiative evolved
from that process. This initiative is an effort
to reassess the information universe and the
data quality needs of EPA, states and tribes,
and public and private sector customers
involved with hazardous waste management
under the Resource Conservation and
Recovery Act (RCRA). WIN also seeks to
provide unproved access to hazardous waste ^^^^^^^^^^^^^^^^^^^^
information, to reduce the burden of data
providers, and to match information technologies to the identified data and access needs.
A WIN steering committee consisting of representatives from EPA headquarters, regions
(Regions 3, 9 and 10), and states (Oregon, Nevada, and New York) was formed to oversee the
WIN effort. The committee decided to pursue separate but parallel tracks in conducting the
first phase of the WIN project — an Information Strategy Plan (ISP). To ensure comparable
results, a common methodology, the Information Engineering Methodology (IBM), was
chosen. IEM is a top down approach to information systems development that has four
phases: 1) planning (preparation of an ISP); 2) analysis; 3) design; and 4) construction.
This ISP was prepared to provide the EPA hazardous waste program with a vision of the
strategic information needed to support the program over the long term. It also provides a
plan that outlines analyses and projects designed to meet the objectives of the WIN initiative.
The ISP discusses the evolving program directions and documents the supporting activities that
EPA management and staff expect to perform as part of the EPA hazardous waste program in
the future (Program Assessment). It identifies the information needs deemed essential to carry
out these activities effectively (Information Needs Assessment), and assesses the reliability and
accessibility of the automated and non-automated systems and tools that currently supply
information to the program (Current Systems Assessment). The ISP also lists potential
technologies, along with guidelines and assessment criteria for selecting technologies for the
future (Technology Assessment). Finally, it discusses findings and recommendations and
includes EPA's transition (or implementation) plan, which identifies issues to be resolved and
possible mechanisms for proceeding with the next phase.
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This report presents EPA's ISP. The states have already developed an ISP under their parallel
effort, Information Needs for Managing Environmental Decisions (INFORMED). Prior to
initiating the next analysis phase of the project, states and EPA will meet to discuss the results
of the planning phase and to develop a framework for proceeding. The EPA and state ISPs
provide a roadmap to the analysis that will lead to improvements in current systems or the
construction of new ones. These ISPs, however, do not signal the immediate phase out of
current systems that support the RCRA program. As the WIN and INFORMED processes
evolve and these strategic plans are implemented, EPA will continue to maintain and support
current systems until any new or redesigned system(s) are hi place.
STRATEGIC VISION ON RCRA PROGRAM AND ITS INFORMATION NEEDS
Key findings of the program and Information Needs Assessments of this ISP are given below.
EPA's role is changing with regard to the regulated community. Traditional command and
control approaches to setting standards and achieving environmental protection are being
replaced and/or supplemented by more flexible approaches, including voluntary actions and
compliance assistance, that focus on the end result.
EPA's role is changing with regard to its co-implementors. As the hazardous waste program
continues to mature, EPA's role is evolving from one that emphasizes program development
and direct implementation toward one that focuses on evaluation and assistance to the states
and tribes, who are co-regulators of the RCRA program. EPA must also ensure greater access
to program information, including regulatory interpretations, proposed rulemakings, and
guidance documents to states and tribes to ensure consistent implementation of the hazardous
waste program across the nation. As states and tribes exercise more flexibility to set priorities
based on their unique environmental issues, EPA needs to develop new measures of program
progress that reflect this situation.
EPA should place less emphasis on tracking program activities and more emphasis on
developing effective means of measuring program success based on actual environmental
results and stakeholder needs. Historically, EPA has evaluated program performance
primarily by tracking individual program implementation activities. With movement away
from command and control approaches and toward greater flexibility for states to pursue
priority environmental issues, better measures are needed to assess the actual environmental
results (outcomes) of different ways of managing the nation's hazardous waste. The increased
emphasis on compliance assistance also requires that EPA develop tools and mechanisms for
determining stakeholder needs, and establish ways to measure the effectiveness of different
compliance assistance tools hi meeting those needs.
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Hazardous waste program information should be readily available to analysts and the public
at large, less resource intensive to maintain, and of higher quality. Information should be
easily accessible for program staff and managers and readily available to the public to promote
local stakeholder participation in environmental decision-making.
EPA hazardous waste information should be integrated with other EPA and outside
information systems. The EPA hazardous waste program has a rapidly increasing need to be
able to integrate its information systems with others in order to support multi-media activities,
risk analyses, Agency reinvention and regulatory reform initiatives, and other targeting and
prioritization efforts. This is particularly true in the area of risk analyses, as EPA
incorporates more risk-based decision making into all program development and
implementation activities, as well as management/budget decisions.
More emphasis is needed on reducing unnecessary burdens on those who must provide
hazardous waste information. As EPA seeks ways to reduce the hazardous waste reporting
burden and devolve the hazardous waste program increasingly to the states and tribes, EPA
needs to identify the fundamental (core) data required to support the EPA hazardous waste
program. EPA needs to also continue to reinvent and streamline the existing program to make
it simpler and less burdensome for facilities to show compliance with environmental
regulations.
The EPA hazardous waste program information needs should drive the development of any
future information systems. EPA's prior experience (particularly with regard to RCRIS
[Resource Conservation and Recovery Information System] Lessons Learned project) has
shown that programmatic definitions should be developed and agreed upon up front by the
program personnel (EPA, states, tribes), and these should be the elements around which
information systems are developed.
The EPA hazardous waste program has numerous information needs, and they do not
appear to be decreasing. The need for information ranges from facility-specific to program-
wide information covering stakeholders, program planning, information systems, and policy
and regulatory documents. New requirements, such as the Government Performance and
Results Act (GPRA), create additional information needs as well. EPA personnel observe a
significant tension between the overall program goal of achieving burden reduction and a
continuing need, at the implementation level, for detailed, site-specific information. One of
the major challenges the program faces is defining a set of core information needs that reduce
the current reporting burden on all stakeholders, yet provide adequate information to allow
effective management and evaluation of the progress of the program on a national level.
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EPA PROGRAM AREAS
A Program Area represents a set of highly-related activities that create and share a common set
of information. Dividing the EPA hazardous waste program into a series of Program Areas
allows future analysis to proceed hi an efficient and ordered sequence. After the Program
Areas were identified, they were prioritized for future actions.
The hazardous waste program is comprised of seven major Program Areas: Program
Implementation, Program Evaluation, Information Sharing, Program Development, Program
Management, Studies and Research, and Program Implementation Support.
EPA's recommended top three Program Area priorities are Program Implementation,
followed by Program Evaluation and Information Sharing (tied). The seven Program Areas
were ranked based on both then* strategic importance to EPA's hazardous waste program, and
the extent to which improved information and/or sources to support the particular Program
Area are needed. In addition, the seven areas were reviewed against specific factors external
to OSW that impact priority setting. These external factors include: 1) broad Agency
initiatives (such as the Common Sense Initiative and the 25% Burden Reduction Initiative), 2)
projects/initiatives of other program offices which affect RCRA and/or WIN, and 3) General
Accounting Office (GAO) and Office of Inspector General (OIG) audits/evaluations. Previous
OSW projects and decisions (i.e., RCRIS lessons learned and changes to the 1997 biennial
report) have also created expectations and, therefore, impact priority setting. The results were
that Program Implementation, Program Evaluation and Information Sharing were the three
highest priorities.
Significant overlap exists between EPA's priority Program Areas and the states ranking in
their own ISP. After developing its own priority ranking of Program Areas, EPA compared
the results with the state ISP. Although the identified Program Areas were not identical, and
scope and terminology differed, there was significant overlap. This provides a basis for
continued, coordinated efforts with the states and tribes.
CURRENT SYSTEMS ASSESSMENT
The key findings are:
There are more than 50 major information sources (automated and nonautomated) for
RCRA information. Many of these systems are currently available to program staff via the
Agency's mainframe, the Agency's value added backbone services .(VABS), or the Internet
(see Exhibit 4-2). The sources most frequently used are Biennial Reporting System (BRS),
Code of Federal Regulations (CFR), Industry Studies Database (ISDB), Integrated Database
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for Enforcement Actions (IDEA), Resource Conservation and Recovery Information System
(RCRIS), and the Beginning of Year Plan (BYP). These six information sources provided an
information baseline for the EPA hazardous waste program.
National systems (Toxic Release Inventory [TRI], Facility Index System [FINDS], RCRIS,
BRS, Integrated Data for Enforcement Analysis System [IDEA], Comprehensive
Environmental Response, Compensation and Liability Information System [CERCLIS])
received the lowest confidence levels because these mainframe systems are considered to be
medium in reliability and low in accessibility. While program staff frequently access these
systems, and acknowledge that these sources contain a wealth of information on facility,
wastes, and program activities, they rated the reliability of information as medium.
They note that the information is not as current as needed, and that it does not provide
the flexibility needed to support multi-media and risk analyses. Information sources such as
RCRIS and BRS, which are maintained within the EPA hazardous waste program, are
difficult to access because they are on the mainframe and programmed in a software language
(FOCUS) that is difficult to use. Other sources that are maintained outside the EPA hazardous
waste program are not readily accessible to staff. Data consistency and reliability issues
should be continuously addressed when information is collected from diverse suppliers.
Nearly half of the information sources used are maintained by organizations external to
EPA/RCRA programs (e.g., CERCLIS). Other organizations within EPA that are responsible
for the information sources identified include the Office of Emergency and Remedial Response
(OERR), the Office of Research and Development (ORD), the Office of Prevention, Pesticides
and Toxic Substances (OPPTS), and the Office of Information and Resources Management
(OIRM). The need to access and integrate external information sources will become
increasingly important as program staffs strive towards the vision of an integrated
environmental approach.
Significant reliance on textual information indicates that strategic information management
needs cannot be met solely through automated data base applications. Headquarters and
regional program staff often use sources that contain textual information on Agency
regulations, policies, guidance, studies, and decisions. This type of information is typically
organized in repositories that are hard copy or electronic. If the repository information is in
hard copy, it may be found in an organizational library or on a staff member's desk. If the
repository information is electronic, it may be located on the Internet to widen its availability
or located on a local area network (LAN) server to make information available to internal
organizational staff.
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TECHNOLOGY ASSESSMENT
The ISP lists potential technologies to be considered and proposes evaluation criteria to be
used hi making future decisions on information technologies to support the hazardous waste
program.
The key findings are given below.
EPA needs to seek stakeholder involvement prior to making recommendations on any
specific information technology (or technologies) for the hazardous waste program. Input on
potential technologies and likely applications needs to be solicited from hazardous waste
program stakeholders. It is also essential that EPA, states, and tribes resolve certain
programmatic issues (e.g., co-regulation roles) prior to any selection of specific technologies.
Future technologies should be able to accommodate and focus the broad range of technology
and information requirements of the hazardous waste program stakeholders, be user
friendly, and support broad sharing and accessibility of information. Given the wide range
of information needs and the diversity of skills across the stakeholder universe, any national
approach to information management for the hazardous waste program needs to provide a
variety of automated information collection methods, and access tools. Users must be able to
access the information they need and have it organized and presented in a manner that is
meaningful and useful to them.
To effectively support new program directions, new technologies need to facilitate the
integration of information from many sources. New program directions focus on solutions
that consider the place (community-based programs/projects), multi-media impacts, a
particular industrial sector, and measurable environmental results. Technologies, therefore,
should easily support linking and combining hazardous waste information with information
from other sources that describe other environmental media, population demographics, and
industry demographics.
Any technologies considered for a national hazardous waste program information system
must be evaluated against a set of criteria that reflects user requirements. EPA has
developed a set of criteria (user requirements) to be used in evaluating technologies. The
criteria are reliability, accessibility, cost, flexibility, portability, useability, infrastructure
compatibility, telecommunications requirements, processing requirements, system security,
electronic media information access, scalability, and historical record keeping ability.
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TRANSITION (OR IMPLEMENTATION) PLAN
EPA has developed a proposal for the next analysis phase of the WIN process. This transition
plan includes recommendations for actions over the next 2-3 years, and proposes guidelines
and key principles for interaction with states (and tribes where feasible) in carrying out the
next phase of the project. The following paragraphs present the key findings.
The priority Program Areas-Program Implementation, Program Evaluation, and
Information Sharing-are proposed for action, and possible completion, over the next two to
three years. Since it is not possible to address all of EPA's short- and long-term information
management needs in the next two or three fiscal years, priorities must be set. The Transition
Plan recommends that the top three priority Program Areas be targeted for action.
EPA has identified several important short-term projects for action in FY1997. Rather than
focus all of its available information management resources on Program Area Analyses
(PAAs), EPA believes it is important to capitalize on some of the short-term projects
underway or about to begin, and to realize some short-term successes. The priority short-term
projects EPA will pursue in FY 1997 are implementing the 1997 Biennial Report changes to
support burden reduction, developing a searchable database of policy and guidance documents
on the Internet for easier public access, streamlining the RCRIS national oversight data base,
developing a copy of the national oversight systems for RCRIS and BRS in Oracle to provide
for increased data sharing and integration across the agency, and conducting a feasibility study
on a docket indexing system that supports EPA's desire to make all docket systems
compatible. Each of these short-term projects supports one of the top three priority Program
Areas, or is needed to fulfill an agency mandate.
Each PAA and short-term project should address certain key principles. These principles,
based on past experience and future program directions, are fundamental to the success of any
future national information management initiative. They are 1) identification of core (truly
essential) information needs to reduce burden, 2) development of consistent definitions, 3)
establishment of an agreed upon partnership framework (including resolution of co-regulation
issues), 4) provision for increased accessibility to information by all industry sectors, EPA
staff, states, tribes, stakeholders, and 5) support for a multi-media focus (ability to integrate
systems).
EPA, states, and, if possible, tribes need to agree on a framework for interaction early in the
transition process. Prior to initiating the next phase of the process, the PAA, EPA, states and
tribes (as feasible) will meet to determine the specific next steps and to identify roles and
responsibilities associated with carrying out those steps. The transition plan discusses the need
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to agree on a framework for interaction early hi the implementation process. The framework
should address a methodology for conducting the PAAs to ensure consistency across PAAs, a
process for developing and reaching agreement on work plans with tasks and deadlines, and
mechanisms for resolving issues that arise during the process.
Continued success for the WIN initiative requires a long-term resource commitment. To
implement the findings of the ISP, the transition plan reflects the Agency's attempt to strike
the optimum balance between resource and time constraints versus the necessity for
meaningful progress on critical long-term and short-term projects relevant to EPA's
information management systems. The Agency estimates that the WIN initiative will take
several years to complete. This estimate includes the completion of several activities. First,
the highest priority Program Areas must undergo a detailed five-step analysis comprising the
following tasks: scoping a PAA, activity analysis, data analysis, interaction analysis, and
confirmation. Second, the remaining Program Areas must be reviewed. Additionally, there
are a number of short-term projects underway or scheduled to be initiated in the near future
that will support the purpose and goals of the WIN initiative.
EPA and the states must make a long-term commitment to the WIN initiative and provide the
necessary resources to effectively implement this effort. The commitment must include not
only the identification and acquisition of the next generation of information systems that
emerge from the WIN and INFORM initiatives, but also ongoing support to those systems
after they become operational. It is also essential to continue supporting existing information
systems during the transition, with an eye toward where the next generation of information
systems are headed.
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1.0 INTRODUCTION
This report, which is a strategic planning document for information management, is the first
step of a four-stage process that the Resource Conservation and Recovery Act (RCRA)
program is undertaking to systematically identify RCRA hazardous waste information needs
and develop and implement approaches to meet those needs.
The Office of Solid Waste (OSW) believes this project is vital to ensuring that needed
information is available for the Environmental Protection Agency (EPA) to efficiently and
effectively develop and implement a RCRA program evaluation; offer program support,
technical support, and state assistance; and review existing and develop new regulations and
guidance. OSW further believes that meeting RCRA program information needs will ensure
an integrated and effective hazardous waste management program in the United States.
Without a systematic review of RCRA information needs and an integrated approach to
developing new information management systems, EPA will not be successful in transitioning
from current, burdensome mainframe based systems to future systems that provide better
accessibility and key information to meet the changing requirements of the RCRA community.
1.1 BACKGROUND
It has been almost 2 decades since the EPA embarked upon a comprehensive national program
for hazardous waste management known as Subtitle C of RCRA. During this time, the RCRA
program has achieved a number of successes, including the establishment of a nationwide
cradle-to-grave system of hazardous waste management. In addition, both the public and
private sectors have expended substantial efforts to reduce hazardous waste generation, recycle
or treat hazardous wastes prior to disposal, ensure proper disposal, and take corrective actions
where necessary to clean up old contaminants.
From the outset the RCRA program has featured a significant role for the states, delegating
implementation authority to the states over tune. By the mid-1990's, the program has become
much more of a state-delegated program, which has involved changes in emphasis on the
respective roles and responsibilities of EPA, the states, and more recently, tribal authorities.
The OSW has endorsed this evolving direction and, through its five-year Strategy, is
committed to changing its operations to further this direction in program management.
The vision statement from the OSW Strategy (see Appendix A) indicates EPA's intent:
To move from a primarily command and control program and from the role of direct
implementor to a more flexible, innovative, and delegated program. Through assistance
and dissemination of information, [EPA will] leverage the resources of others to
implement the program.
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The OSW Strategy provides the following objectives for the management of information, which
is a key factor in the vision statement:
• The states, tribes, and EPA mutually agree to the core data elements needed to support
the National RCRA program. Using these elements as a template, the states and tribes
identify other elements to assist them in managing their programs.
• EPA maintains a database to support national-level information needs; the states and
tribes maintain their own RCRA data systems that feed into the national system.
• EPA develops a national-level RCRA information system consistent -with the Agency's
integrated information management system.
• EPA effectively integrates data management into regulatory development and
implementation.
• EPA significantly reduces the overall RCRA record keeping and reporting burden.
• EPA develops and utilizes a much better understanding of the real risks (human health
and ecological), and significantly improves its ability to measure and communicate
information about those risks.
• EPA redefines RCRA success measures to focus on outcomes.
The Waste Information Needs (WIN) initiative evolved from the objectives of the OSW
Strategy. This initiative is an effort to reassess the RCRA information universe and the data
quality needs of states and tribes, EPA, and public and private sector customers. The WIN
initiative is also an attempt to improve access to hazardous waste data and reduce the burden
of data providers. Finally, the WIN effort seeks to match its information technologies to the
identified data and access needs.
1.2 DISCUSSION
In developing the WIN project, EPA established a steering committee of headquarters,
regional (3, 9, and 10), and state (New York, Nevada, Oregon) representatives. The first task
for the steering committee was to determine the scope of the WIN project and the method by
which the states and EPA would reassess information needs.
The steering committee decided that because the hazardous waste program and the municipal
program are fundamentally different, WIN would initially focus solely on hazardous waste
management. The committee also felt that it would take a concerted and comprehensive effort
to work out the complex information needs and relationships of just the hazardous waste
information stakeholders.
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During several planning meetings in April and May 1995, the states and EPA discussed
changes in their respective roles and information needs in implementing the hazardous waste
program. Through these discussions, the states and EPA decided to conduct two separate but
parallel efforts to determine state, tribal, and EPA information needs.
[NOTE: Because the role of tribes in implementing RCRA programs is still in
its early stages of development, the state experience is, at this point, being used to
suggest by analogy future tribal needs. We anticipate that direct input from the tribes
will be forthcoming in response to this Information Strategy Plan and in the
implementation phase of the program. To the extent that tribes are in a position to
participate directly, EPA welcomes such participation.]
The steering committee determined that it would oversee these two efforts. The committee
also agreed that there would be a common approach (i.e., the Information Engineering
Methodology - IBM) used by both the states and EPA in determining the information needs.
The IBM is a top-down approach to information systems development consisting of four
phases: 1) planning (preparation of an ISP), 2) analysis, 3) design, and 4) construction. The
steering committee will meet in November 1996 to determine the next steps after the two ISPs
are completed by EPA and the states. The body of this report does not describe the details of
the approach used to conduct this ISP or the method used to analyze and prepare the results.
This information is described in detail hi the appendices. Appendix B provides a detailed
description of the overall IBM approach, including the development of this ISP and the follow-
on phases. Appendix H focuses on the key analytical steps of the IBM approach used to
perform this ISP.
This document is the Information Strategy Plan (ISP) for the EPA hazardous waste program,
and it identifies the following:
• Expected goals and activities of the EPA hazardous waste program.
• Strategic information needs for supporting the EPA hazardous waste program.
• Major Program Areas for analysis (groupings of program functions and their
information support requirements).
• Current sources used to acquire information and the reliability and accessibility of the
information.
Possible technology strategies to be considered hi the future collection, integration, and
dissemination of information.
• An analysis of the above hiformation to establish information priorities for the
hazardous waste program for EPA.
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• An implementation plan to carry out the major findings in this ISP.
The document does not identify activities or data elements, particularly the following, at a
detailed or comprehensive level:
• Specific activities of the hazardous waste program.
• Specific data elements or their data quality requirements.
• Data element sources.
• Specific technology solutions.
• Every information-related activity needed to support the hazardous waste program.
The next phase of the overall WIN effort, Program Area Analysis (PAA), will address these
specifics, including data quality and access requirements. This EPA ISP will be used in
conjunction with the state ISP (INFORMED - Information for Making Environmental
Decisions) to determine the next steps that the states and EPA will be taking together (and
separately) hi pursuing a coordinated set of priorities. By coordinating the two ISPs and future
planning, both EPA and the states can ensure the best use of resources in managing RCRA
hazardous waste information needs for all interested parties, including members of the general
public.
1.3 ORGANIZATION OF THE REPORT
The remainder of this report, which provides the results of the EPA hazardous waste program
ISP, is organized into six chapters. The contents of each chapter are described below, along
with key questions answered in the chapter:
• Chapter 2.0, The EPA Hazardous Waste Program Assessment, identifies the EPA
offices and divisions currently involved in managing, evaluating, and directing the
national hazardous waste program and addresses the implications of their respective
activities and overall visions for information management. This chapter addresses the
following questions:
- Which EPA organizations primarily support the hazardous waste program ?
— What are management's views from the EPA organizations supporting the
hazardous waste program?
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- What are the key strategies of EPA management and staff to implement the
hazardous waste program ?
Chapter 3.0, Identification of EPA Hazardous Waste Program Areas and
Information Needs, describes the information needs and activities to support the
current and anticipated future direction of EPA's hazardous waste program. This
chapter addresses the folio whig questions:
- What underlying program activities and information needs are interrelated to
form a Program Area and what are those Program Areas?
- Do the results suggest that there are any program issues that management must
examine and resolve?
Chapter 4.0, EPA Hazardous Waste Program Current Systems Assessment,
discusses the current sources of information, including automated and non-automated
systems, used by the EPA hazardous waste program. This chapter addresses the
folio whig questions:
- What are the major sources of information currently used to support the EPA
hazardous waste program?
— What are the major gaps and weaknesses for hazardous waste information
support?
Chapter 5.0, Potential Technologies and Evaluation Considerations, discusses
guiding principles that should be considered when selecting information technology
solutions to support emerging information needs of hazardous waste program activities.
This chapter addresses the following questions:
— What are some information technologies that can potentially improve EPA's
ability to satisfy its hazardous waste information needs?
- What characteristics should be considered when evaluating technologies?
Chapter 6.0, Program Area Prioritization and Recommendations, identifies the
respective priorities of the Program Areas to be explored, identifies other influences
and factors that affect information-related projects, and proposes specific information
management projects to be conducted. This chapter addresses the following questions:
— Which Program Areas need to be analyzed first?
— Which Program Areas have the highest strategic importance?
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— Which Program Areas have information needs requiring the most improvement?
— What are the external and internal Agency influences that may affect Program
Area priorities? Do the Program Area priorities change based on these factors?
— What short-term projects have been identified in response to external and internal
Agency influences?
Chapter 7.0, Transition Plan, identifies the near-term hazardous waste information
projects to be conducted and addresses the order and schedule for completing the
projects. This chapter address the following questions:
— What is EPA's proposed Program Area Analysis (PAA) plan, including projects,
resources, schedules, and outputs/outcomes?
— What are the key principles to consider in conducting the PAAs and short-term
projects?
— What are the issues concerning the successful coordination of EPA (both
headquarters and regions) and state PAAs, and what is the appropriate
frameworkfor resolving these issues?
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2.0 THE EPA HAZARDOUS WASTE PROGRAM ASSESSMENT
This chapter discusses the assessment of the EPA hazardous waste program and addresses the
following areas:
• Key questions answered by this chapter.
• Key findings of the hazardous waste program assessment.
• Discussion of EPA hazardous waste program organizations and functions, senior
management views of program direction and information management from the
perspective of the primary RCRA organizations (i.e., OSW, OECA, regional offices),
and the RCRA strategies required to implement the program.
2.1 KEY QUESTIONS
Which EPA organizations primarily support the hazardous waste program?
What are management's views from the EPA organizations supporting the hazardous waste
program?
What are the key strategies of EPA managment and staff to implement the hazardous waste
program?
2.2 KEY FINDINGS
Findings are presented for the organization of the EPA hazardous waste program, the direction
of the program, and the direction of information management.
2.2.1 Organization
• The EPA hazardous waste program is supported primarily by several organizations:
OSW within the Office of Solid Waste and Emergency Response (OSWER), Office of
Enforcement and Compliance Assurance (OECA), and the hazardous waste divisions in
the 10 EPA regional offices.
• EPA's role is evolving from an emphasis on program development and implementation
toward one with more emphasis on evaluation and program improvement. A major
thrust of the future RCRA program is movement toward a more state-
delegated/operated program, thereby reducing EPA's direct implementation function.
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2.2.2 Program Direction
• EPA's approach to promoting environmental protection (including the hazardous waste
program) is changing from command and control regulatory activities to providing
more flexibility hi achieving environmental protection, including expanded use of
voluntary actions and initiatives.
• In the future, all RCRA organizations will likely place less emphasis on program
activities and more emphasis on environmental results to measure program success.
• A greater emphasis on compliance assistance activities will require the development of
measurement techniques to determine stakeholder needs and the effectiveness of
different compliance assistance tools in meeting those needs.
• EPA must continue to reinvent and streamline the existing program to enhance the
Agency's ability to meet its mission in an era of increasingly constrained resources and
to make it simpler and less burdensome for facilities to show compliance with
environmental regulations and other performance standards.
• The EPA hazardous waste program activities will need to be integrated with EPA's
multi-media approaches to environmental protection.
• The EPA hazardous waste program will be incorporating more risk-based decision-
making into all program development, implementation, and evaluation activities.
2.2.3 Information Management Direction
• The information needs of the EPA hazardous waste program should drive the
development of information systems. The information systems should not drive
hazardous waste program activities.
- Program decisions and program activities should not be dictated only from
information available hi a national system.
— Definitions used hi substantive program activities should be standardized and
developed directly by the program personnel before being collected and stored
in an information system. The information system should not force definitions
by selecting data hi a particular way.
• Information must be made available and explained to the public to promote local
stakeholder participation in permitting, compliance, and other community-based
activities (especially as multi-media decision making increases).
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• Hazardous waste information must be integrated with EPA information systems, as
well as other outside information systems, to support multi-media activities.
• Hazardous waste program information must be more readily available to users, less
resource-intensive to maintain, and of higher quality to support quality scientific and
technical analyses.
• Minimizing the burden on the reporting community must be a priority consideration
when identifying the information needed to support the EPA hazardous waste program.
• To help reduce unnecessary burden on the reporting community, EPA must strive to
identify and maintain fundamental core information to support the hazardous waste
program and must focus burden reduction efforts on non-fundamental core information.
• To promote consistent implementation of the hazardous waste program at EPA
headquarters and the regions, EPA must provide greater access to certain specific types
of program information (e.g., regulatory and policy interpretations, rule makings with
background documents, and guidance materials).
2.3 DISCUSSION
EPA used a five-step assessment process to identify the overall goals, strategies, and activities
in its hazardous waste program (See Exhibit 2-1). Once identified, these goals, strategies, and
activities were then used to identify and group information needs of the EPA hazardous waste
program (discussed in later chapters of this report).
[NOTE: the relationship of this process to the Government Performance and Results Act
(GPRA) and OSW's strategic planning process is presented in Section 2.3.2.]
The first step involved interviews with senior management from OSW, OECA, the Office of
Information Resources Management (OIRM), and regional offices. (Appendix C contains a list
of the managers who were interviewed.) During the second step, several RCRA hazardous
waste program experts drafted a list of program activities. The third step consisted of focused
sessions with program representatives to identify their strategies and expected activities hi the
next 5 years and to identify associated information needs (see Chapter 3). In preparing for
these sessions, facilitators compiled information from OSW's Strategic Plan (Appendix A) and
other Agency planning documents (Appendix D contains iiiformation on Agency initiatives)
and presented this information to participants so they could formulate the goals and strategies
of the EPA hazardous waste program. The fourth step involved a national meeting held in
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Process/Players
Activity
Step 1
Step 2
Steps
Senior management
interviews
(Spring '95)
Headquarters team
of program experts
(Spring '95)
Focused sessions
with program
representatives
(Summer/Fall '95)
Defined program vision
Identified program goals and
strategies
Identified high level program
activities
Reviewed OSW Strategic Plan
and other planning documents
for information on Agency goals
and strategies
Refined program goals,
strategies, and activities
Identified information needs
associated with strategies
Step 4
National session
with headquarters
and regional staff
(Fall '95)
Reviewed/refined program goals,
strategies, information needs
Grouped information needs into
activity categories
StepS
Headquarters team
of program experts
(Winter/Spring '96)
Refined/supplemented list of
activities, information needs
Grouped needs into categories
for future analysis
Exhibit 2-1. Five Steps hi EPA's Hazardous Waste Program Assessment
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September 1995 that brought together program staff and managers to combine, better
categorize, and prioritize the goals, strategies, activities, and information needs identified in
the earlier steps. (See Appendix E for List of Participants in the September 1995
Headquarters/Regional Meeting.) The final step consisted of internal revision and
supplementation (for completeness) of the products from earlier steps.1
2.3.1 EPA Hazardous Waste Program Organizations and Functions
Several organizations within EPA share responsibility for development and implementation of
the Agency's hazardous waste program. Within EPA, two headquarters offices (OSW and
OECA) and the hazardous waste divisions in the 10 regional offices are primarily responsible
for the development, implementation, oversight, and evaluation of the hazardous waste
program. Through the RCRA delegation process known as "Authorization", individual states
have assumed or will be assuming responsibility from EPA for specific program elements
(e.g., permitting, inspections, and enforcement). For those program elements that have not
been delegated via the authorization process, EPA retains responsibility for program
implementation. Exhibits 2-2, 2-3, and 2-4 summarize the roles of different offices or
divisions within the three major EPA organizations responsible for the hazardous waste
program. In addition, OIRM plays a major role in establishing standards and monitoring the
information management activities of EPA.
2.3.2 Senior Management View of the EPA Hazardous Waste Program
Senior management in OSW, OECA, OIRM, and the regions were interviewed to obtain:
Their insight on information needs of the EPA hazardous waste program.
Their vision for program activities over the next 5 years.
The types of decisions required.
The information needed to support these decisions.
Their expectations for the WIN initiative.
1 Other offices that participate in or directly affect aspects of RCRA activities and that
have not yet participated in this process include the Office of Research and Development
(ORD) and the Office of General Counsel (OGC). The views of these organization will be
incorporated through the review process of this document. These organizations are important
hi many ways to the effort of reinventing information management for the EPA hazardous
waste program. For example, ORD supports the program with studies on risk, treatment
performance, and pollution prevention options, and OGC needs and uses information to
support litigation and to advise program staff on developing legally defensible regulations and
policies.
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OSW was created to implement RCRA. This office comprises the following six divisions:
• Hazardous Waste Identification Division (HWID) - Identifies wastes and criteria that
should be regulated as solid and/or hazardous, as well as those wastes currently in the
hazardous waste program that should be exempt from regulation.
• Permits and State Program Division (PSPD) - Develops standards and guidance for
permitting and oversight of the state authorization program and tribal activities. The
division also is responsible for developing rules, guidance, and policies for corrective
action and munitions.
• Hazardous Waste Management and Minimization Division (HWMMD) - Develops land
disposal restriction standards, emission standards, and other regulations governing the
burning of hazardous waste, the waste minimization program, and capacity assurance
analyses. It also has die co-lead within OSW for the WIN initiative.
• Economics, Methods, and Risk Analysis Division (EMRAD) - Performs risk and
economic analyses of proposed and existing regulations and develops analytical methods
for analyzing waste.
• Communication, Information, and Resource Management Division (CIRMD) -
Performs budget planning and allocation for OSW, information technology management,
and outreach to the public (e.g., RCRA Hot-Line). The division also has the co-lead within
OSW for the WIN initiative.
• Municipal and Industrial Solid Waste Division (MISWD) - Develops standards for
facilities that manage industrial Subtitle D wastes, provides regions with support for the
state municipal landfill permitting program, and develops procurement guidelines for
recycled materials.
Exhibit 2-2. Roles of Divisions within the Office of Solid Waste
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OECA is organized to address media-specific issues, as well as provide enforcement and
compliance assistance by industrial sector across media (e.g., air, water, land releases for the
petroleum sector). Essentially, the five offices within OECA, identified below, support the
EPA hazardous waste program in one way or another, although only one of those offices has a
division specifically set up to handle RCRA-only enforcement issues.
• Office of Compliance (OC) - Activities in this office include developing voluntary
compliance programs,Jsupporting information management, identifying compliance
assistance tools and assessing their effectiveness, analyzing trends in noncompliance,
targeting facilities for compliance assistance, establishing RCRA specific priorities, and
evaluating regional Memoranda of Agreement (MOA).
• Office of Regulatory Enforcement (ORE) - ORE emphasizes a more traditional
enforcement approach. Activities in this office include developing guidance for
enforcement, conducting outreach and work groups, developing regulations, supporting
enforcement cases, and conducting targeting and prioritization, particularly for input
into MO As.
Office of Site Remediation and Enforcement (OSRE) - OSRE concentrates primarily
on developing and evaluating compliance with the Corrective Action Program (i.e., site
cleanup). OSRE's activities include rule makings, identifying alternatives to RCRA
corrective measures, and improving the efficiency of the Corrective Action Program.
• Office of Federal Facilities (OFF) - OFF responsibilities include overseeing the
compliance of federal facilities with EPA's environmental regulations, including
RCRA. The major activities of this office include conducting inspections, conducting
oversight of clean-up activities, and providing assistance with corrective action orders
and legal jurisdictional matters.
• Office of Criminal Enforcement (OCE) - OCE is the criminal investigation arm of
EPA with respect to actions that harm the environment and/or human health. The
major activities of this office include case screening and targeting, as well as preparing
information to support criminal cases.
Exhibit 2-3. Roles of the Offices within the Office of Enforcement and Compliance
Assurance
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Some regions have organized their RCRA activities into separate hazardous waste divisions,
while others are organized into multi-media groups, similar to OECA. Though the activities
may vary somewhat from region to region, the following core activities are similar in every
region:
• Permitting and Corrective Action - The regions prepare permits, evaluate the
progress that states are making in issuing permits, and conduct and oversee facility
evaluations and cleanup.
• Compliance and Enforcement - The regions perform compliance assistance, set
priorities for inspections, conduct inspections, issue enforcement orders, ensure
correction of non-compliance, write orders, work on criminal investigations, and track
compliance.
• Waste Minimisation - The regions develop waste minimization programs, allocate
grants for states and facilities to pursue waste minimization, and target waste
minimization activities.
• Information Management - The regions collect data to track facility and program
status, support targeting efforts, track state and tribal programs according to grant
agreements, and evaluate programs.
• State Authorization and Program Development - The regions review state
authorization applications to ensure consistency with federal RCRA program
requirements. Regions review and approve state and tribal grant applications for EPA
funding to perform RCRA program implementation activities (i.e., permitting
corrective action, enforcement). Regions provide technical assistance to states and
tribes to improve their programs.
Exhibit 2-4. RCRA-Related Roles within EPA Regional Offices (e.g., Hazardous
Waste Divisions)
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These interviews are summarized from the perspective of the key EPA RCRA organizations
and are presented below.
OSW Management View of the EPA Hazardous Waste Program
In general, OSW managers saw the role of their program changing from one of less emphasis
on developing new regulations to one with more emphasis on promoting flexibility and
increased use of voluntary programs, such as waste minimization and implementation
assistance. A heavy emphasis on information dissemination is central to this evolving role. In
developing programs, either regulatory or voluntary, OSW managers noted that a greater focus
will be placed on conducting risk assessments and on identifying and using environmental
indicators for evaluating program progress and for targeting resources and prioritization, also
being addressed through the GPRA project (see Exhibit 2-5).
The Government Performance and Results Act (GPRA) of 1993 requires federal agencies to:
• Develop strategic plans.
• Prepare annual plans setting performance goals.
• Report annually on actual performance compared to goals.
OSW conducted a comprehensive strategic planning process in FY 1994 and has updated the OSW
Strategic Plan for FY 1996 (see Appendix A). The OSW Strategic Plan for FY 1997 will build on
these foundations and will incorporate input from the WIN initiative. In addition, it will be
expanded to meet the GPRA requirements that are becoming effective, particularly as they relate to
performance-based budgeting. The initial Agency-wide strategic plan under GPRA is due in
September 1997; the RCRA component will need to be drafted by March 1997. EPA plans on
using both the FY 1996-1997 OSW Strategic Plan and the strategic vision outlined in Chapter 2 of
this document as the foundation for the OSW component of the Agency's GPRA strategic plan.
Future strategic planning efforts will proceed in concert with GPRA implementation efforts and
will also interact closely with WIN efforts to ensure clear and coordinated direction and
integration. As they become known, FJ»A will incorporate the GPRA requirements, particularly as
they relate to information management, into the follow-on phases of the WIN initiative.
Exhibit 2-5. Coordination between GPRA and RCRA Strategic Planning
Given these program directions, OSW managers noted that some of these evolving roles will
have heavy implications for information management. Specifically, the need to take risk into
account during any regulation development activities and program targeting efforts will require
detailed data (e.g., toxicity, fate-and-transport receptor, and economic analyses data).
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Currently, adequate and accurate information is often not available. The need for additional
information must be weighed with the ongoing effort to reexamine the burden to the regulated
community.
As EPA grapples with identifying measures of environmental performance and takes a more
multi-media approach to the program, OSW managers recognized the need to seek out other
databases, outside of OSW and EPA if necessary, that could assist the Agency in presenting a
more integrated view of a facility's environmental status. Further, they realized that multi-
media approaches may lead to more consolidated reporting at a facility level.
OSW managers also noted the importance of more community-based approaches and decision
making to achieve environmental protection (e.g., Brownfields, Project XL program, Common
Sense Initiative). These projects emphasize the need for a flexible RCRA program that
focuses more on results and not as much on process. Moreover, OSW senior management
recognized the significance of the changing nature of their role in the EPA hazardous waste
program in terms of increasing community outreach and communication with program
stakeholders (regions, states, tribes, regulated community, and the public). OSW managers
also noted the importance of the reinvention of regulations and the continuous evaluation and
improvement of programs. As a result, OSW will need timely, accurate, and useful
information for internal analysis and external review.
OECA Management View of the EPA Hazardous Waste Program
OECA senior managers identified similar evolutionary changes in OECA's roles. Specifically,
they determined that the emphasis on compliance assistance was leading the program towards
the development of voluntary programs. In addition, OECA managers noted that the program
needed to increase consideration of risk information when conducting targeting for
enforcement and compliance assistance. They recognized the clear requirement to develop
environmental indicators reflecting real world outcomes and to use such indicators in
evaluating the program. OECA managers placed an even greater emphasis on conducting
multi-media analyses and targeting and on developing enforcement and compliance programs
by industrial sector.
In emphasizing the multi-media and industrial sector approach, OECA managers clearly
outlined the requirement to integrate Agency databases and provide useful data (i.e.,
consistent, high quality) for sector-based analyses. They further emphasized the requirement
for consolidated databases that would ultimately present an integrated view of individual
facilities. In addition, they found that OECA's focus on compliance assistance and voluntary
programs (e.g., supplemental environmental projects) is creating a requirement to formally
track voluntary compliance and multi-media inspection results as part of information
management. OECA managers emphasized the importance of clearer definitions of state and
federal roles as part of information management and of making information dissemination to
the public a driving force in the Agency's information management efforts.
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Regional Management View of the EPA Hazardous Waste Program
Regional managers highlighted the significance of the evolutionary migration of EPA's role
from traditional program implementation to program evaluation and combined technical
assistance/program implementation. Regional managers noted that information dissemination
will become increasingly important as EPA's role changes. They discussed the importance of
state partnerships hi determining how the program will be implemented.
In addition, regional managers emphasized the requirement to explore alternatives to the
existing paradigms of implementing the hazardous waste program (e.g., alternatives to
permitting, alternatives to RCRA corrective action activities). They also discussed the
importance of developing meaningful environmental indicators to measure progress of the
hazardous waste program and satisfy requirements of the 1993 Government Performance and
Results Act.
In terms of information management, regions were viewed as facing challenges similar to
headquarters. The information management challenges identified included developing
consistent state and federal data, collecting and managing data to support meaningful
environmental indicators, collecting data measuring the effectiveness of compliance assistance
and other tools, working toward development of integrated databases to support multi-media
and placed-based analyses, and providing data to enable decisions to be made based on risk.
Other Management Views of the EPA Hazardous Waste Program
As mentioned above, managers from OIRM were interviewed to assess their view of the
hazardous waste program. OIRM is part of EPA's Office of Administrative Resource
Management and is responsible for developing policies and procedures, as well as information
and technical architectures, to support Agency-wide system development and integration
efforts. Within OIRM, one of the divisions, the Enterprise Technology Services Division
(ETSD), is the organization responsible for offering mainframe, Internet, electronic mail, and
local area and wide area network services. ETSD has been integral to providing the
infrastructure for the current EPA systems that support the hazardous waste program.
ETSD views the information challenges of the EPA hazardous waste program as being similar
to those of other Agency environmental programs. ETSD notes that it is important for EPA to
concentrate on correctly identifying the information needed to support the EPA program and
not attempt to define the states' information needs.
ETSD is also actively involved in identifying various business information architectures that
promote information integration and dissemination as a mechanism for stakeholder
involvement. ETSD believes one of EPA's greatest challenges will be EPA/stakeholder
coordination. As information collection and dissemination moves towards more complete state
control, EPA and states will need to coordinate concerning the information that will be
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consolidated and supported at the national level for EPA and public use. In addition, the role
of technology hi such a state-delegated model will become increasingly important because of
the volume of information that will be transmitted.
2.3.3 Strategies of the EPA Hazardous Waste Program
Eight program-specific facilitated sessions and one national meeting were conducted during
summer 1995 with managers and staff from each RCRA hazardous waste program office to
determine the EPA RCRA community information needs.
The participants in this process first identified an overall program mission and goals to achieve
that mission. Exhibit 2-6 presents the collective program vision of participants in the facilitated
sessions. Appendix F provides a more detailed description of the program goals and strategies
developed at these meetings. For each long-term program goal, EPA program assessment
participants described what strategies could be used and what actions and resources would be
necessary to achieve the goal. In so doing, they identified approximately 150 key strategies.
These were subsequently refined and supplemented to total approximately 200 strategies, listed
in Appendix F.
To facilitate further discussion and use in the WIN initiative and this ISP, the program
assessment participants then grouped the 200 strategies into the six categories identified hi
Exhibit 2-6. The following paragraphs provide detail on these strategic categories.
[NOTE: These strategies are being used as an interim analytical tool to identify the
information needs portion of this ISP, which is the subject of Chapter 3. Overall
information-related strategies for the WIN initiative itself will emerge in subsequent
analysis of the ISP results.]
Program Improvement Strategies
These strategies describe specific actions identified by session participants that should be
implemented to improve the effectiveness (i.e., reduce costs, greater environmental protection,
streamlining) of existing program activities. They also describe the actions necessary to
develop and implement new program activities. Specifically, many strategies in this category
deal with introducing regulatory flexibility into the program and introducing non-regulatory
programs that provide facilities with incentives to manage hazardous waste hi a sound manner
(e.g., pollution prevention and waste minimization programs, Common Sense Initiative, and
Project XL). In addition, a number of strategies focus on improving the internal operations of
EPA through streamlining and burden-reduction efforts. Finally, a large number of strategies
deal with improving relationships with stakeholders, such as the states and the regulated
community, through stakeholder feedback and improvements in program assistance (e.g.,
outreach, technical assistance).
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EPA Program Goals
RCRA is protective of human health and the environment and focuses more on results than process.
EPA provides RCRA information that is accurate, accessible, easy to use, and useful.
The hazardous waste program's effectiveness in protecting human health and the environment can be
measured and demonstrated.
EPA maintains effective and efficient partnerships with stakeholders.
The RCRA program integrates a multi-media environmental protection approach.
The RCRA program is based on sound science.
RCRA is easy to understand.
RCRA promotes source reduction and waste minimization.
Categories of EPA Program Strategies
Program Improvement - Includes strategies for specific reinvention actions that must be
implemented to improve the effectiveness (e.g., reduce costs, promote greater environmental
protection, improve partnerships, reduce burden through streamlining) of the existing program
activities and actions necessary to develop and implement new program activities.
Information Dissemination - Includes strategies for disseminating information about the EPA
hazardous waste program to the RCRA stakeholders to empower decision makers at all levels.
Information Gathering - Includes strategies for gathering information about stakeholder needs,
available technologies, and effective compliance'activities to develop and implement the hazardous
waste program.
Risk-based Decision-Making - Includes strategies about program activities (corrective action
priorities, targeted risk-based waste reduction, budgeting) being developed and implemented
according to the associated risks to human health and the environment.
Program Measurement and Evaluation - Includes strategies for measurement and evaluation of
program tools and effectiveness (e.g., environmental indicators, compliance assistance tools).
Resource Availability - Includes strategies for the EPA hazardous waste program to provide
sufficient resources or identify ways to leverage resources (e.g., manpower, extramural monies,
grant monies) to achieve programmatic goals.
Exhibit 2-6. EPA Program Goals and Strategies as Identified by Program Management and
Staff in 1995 Facilitated Sessions for the Purposes of Identifying Information Needs
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Information Dissemination Strategies
This category of strategies describes specific information (i.e., policy and guidance
documents, facility status, etc.) that should be transmitted to the hazardous waste program
stakeholders. Several strategies describe the requirement to identify fundamental information
about the hazardous waste program and disseminate information about the success of the
program to its stakeholders (e.g., public, regulated facilities, environmental groups). Through
better information dissemination, the community would be increasingly empowered to make
decisions about facilities and to influence the level of compliance and environmental
protection. This category also includes a number of strategies that deal with identifying
effective methods to disseminate information to stakeholders.
Information Gathering Strategies
The strategies hi this category describe specific information (e.g., stakeholder requirements,
available technologies, effective compliance activities) that should be obtained to develop and
implement the hazardous waste program effectively and efficiently. The strategies focus on
the need to gather information from and about stakeholders involved with the hazardous waste
program. Many of the strategies concentrate on understanding stakeholder requirements and
concerns and the use of that information to shape the EPA hazardous waste program. In
addition, some of the strategies focus on improved information gathering approaches, such as
one-stop reporting, reducing the reporting burden by 25 percent, and implementing key
identifiers for facilities [NOTE: Chapter 6 discusses these approaches.]
Risk-Based, Decision-Making Strategies
This category of strategies describes program activities (e.g., corrective action priorities,
targeting, reduction of the most persistent, bioaccumulative, and toxic wastes) that should be
developed, implemented, and/or performed, based on the associated risks to human health and
the environment. The strategies hi this category typically emphasize the need to perform risk-
based, multi-media analyses when developing and targeting program activities. They include
the concepts of incorporating risk into targeting activities, identifying populations and
ecosystems at highest risk, and focusing programs on wastes that pose the highest relative risk.
Program Measurement and Evaluation Strategies
These strategies describe the measurement and evaluation of program results (e.g.,
environmental indicators) and program tools (e.g., compliance assistance tools) that should be
used to assess the effectiveness of various program activities. A number of strategies in this
category discuss the need to have environmental indicators that more directly and meaningfully
measure the progress of the RCRA program in protecting human health and the environment.
Some of the strategies also discuss the need to balance environmental indicators with the
current mode of evaluation based on activity status (e.g., number of permits issued, number of
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RCRA Facility Investigations conducted). This category of strategies is also reflected in
OSW's effort to meet the requirements of the plans and activities for implementing the 1993
GPRA. In this effort, OSW is evaluating program performance in order to prepare the Annual
Program Performance Report required by the GPRA.
Resource Availability Strategies
The strategies hi this category describe how the program can leverage resources (e.g., staff,
extramural monies, grant monies) to achieve programmatic goals. Essentially, the strategies
cover such actions as ensuring that adequate resources are available for assisting public and
private partners in implementing the hazardous waste program and information management
activities.
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3.0 IDENTIFICATION OF EPA HAZARDOUS WASTE PROGRAM AREAS AND
INFORMATION NEEDS
This chapter identifies the seven Program Areas, program activities, and overall information
needs of the EPA hazardous waste program. The Program Areas are based on and reflect the
interrelationships between and among program activities and overall information needs of the
EPA hazardous waste program and represent an important product of the EPA WIN ISP
project. The strategic significance of the Program Areas to the mission, goals, and strategies
of the EPA hazardous waste program and EPA's priorities for Program Area project
implementation are detailed hi Chapter 6 of this report.
This chapter addresses the following areas:
• Key questions answered by this chapter.
• Key findings in the identification of EPA hazardous program areas and information
needs.
• Discussion of key program activities, high level information needs of managers and
staff when performing key program activities, and the seven Program Areas of the EPA
hazardous waste program.
3.1 KEY QUESTIONS
What underlying program activities and information needs are interrelated to form a Program
Area and what are those Program Areas?
Do the results suggest that there are any program issues that management must examine and
resolve?
3.2 KEY FINDINGS
• The EPA hazardous waste program has numerous information needs that range from
facility-specific to program-wide. This broad range of information needs is driven by
the types of activities the program staff will be conducting hi the near term (i.e., 5
years). These activities include efforts related to program development,
implementation, and evaluation.
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• Despite burden reduction efforts, the information needs do not appear to be decreasing.
The WIN project highlights the tension existing between the goal of achieving
significant burden reduction and needs for certain facility-specific information. Also,
certain new requirements introduce new information needs, such as the GPRA. This
tension among the broad-brush goals for burden reduction, better quality information
on environmental and health impacts, and better measurements of those impacts is a
fundamental issue EPA must resolve hi the near future.
• Based on the relationship of underlying program activities and information needs, seven
Program Areas were identified for the EPA hazardous waste program:
Program Development.
Program Evaluation.
Program Implementation.
Program Implementation Support.
Information Sharing.
Program Management.
Studies and Research.
• Regions and headquarters identified information needs hi all Program Areas, although
the frequency and use of those needs varied.
3.3 DISCUSSION
During the executive interviews and facilitated sessions of the EPA program assessment (see
Chapter 2), EPA managers and staff identified 7 key hazardous waste program activities and
46 sub-activities, as well as 65 high level information needs. Further analysis of these results
and the intersections among program activities and information needs led to the identification
of the seven Program Areas. (For a more detailed description of the approach used to identify
the Program Areas, see Appendix H). These Program Areas are the core concept for further
analysis hi this ISP and for identification of the next steps for the WIN initiative.
The program activities discussed hi this chapter encompass EPA's responsibilities for program
implementation, development, and evaluation of its hazardous waste program. The information
needs identified in this chapter represent the entire spectrum of information required by
management and staff hi EPA headquarters and the regions to perform the EPA hazardous
waste program activities and support the EPA hazardous waste strategic vision as discussed in
Chapter 2 of this report. For purposes of this ISP and to encourage the broadest possible input
to the ISP process at this stage, no limitations or restrictions (e.g., streamlining initiatives,
budget constraints) were placed on management and staff in identifying their information
needs. The information needs are considered hi overarching categorical terms and are not
3-2
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intended to represent specific data elements. Further refinement of these information needs
(i.e., specific data element and definitions) will occur as part of follow-on information
management projects that represent the next steps in the WIN initiative.
3.3.1 Key Program Activities
Headquarters and regional staff participated in several facilitated sessions to identify the major
activities of the EPA hazardous waste program. The identification of program activities is the
first step in the process of interrelating program activities and information needs to identify
Program Areas. This process is detailed hi Section 3.3.3 of this chapter.
Participants hi facilitated sessions were encouraged to ensure completeness in the activities
identified and to identify activities common across current organizational lines. For example,
program evaluation occurs within OSW, OECA, and regional offices. In this situation, this
activity was identified only once. The seven key program activities addressed below and in
Exhibit 3-1 cover all 46 sub-activities identified initially by the session participants:
• Program Direction Establishment - Determines the strategic direction of the
hazardous waste program.
• Hazardous Waste and Waste Management Issues Identification - Identifies the
hazardous waste and management issues that must be brought to management and staff
attention for discussion and resolution.
• Program Standards Development - Develops regulatory and non-regulatory standards
to support implementation of the EPA hazardous waste program based on statutory
requirements and program priorities.
• Program Implementation - Encompasses both implementation (hi partnership with
states and tribes) and oversight of the EPA hazardous waste program.
• Environmental Results Monitoring and Evaluation - Assesses the degree to which
program goals and objectives are actually realized hi the environment and provides
feedback for program modifications/enhancements.
• Information Management - Provides the mechanics for collecting, integrating, and
disseminating information to support the EPA hazardous waste program.
• Cross-Cutting Activities - Includes those activities that affect all other activities hi the
hazardous waste program (e.g., collecting and managing feedback to and from
stakeholders, ensuring effective communication).
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T®
;
Hazardous Waste b
and Waste 1 ' ''jaSPI
Management Issues 1 JHkH
Identification - | fiHp"] ! |
• Analyze Industrial Wa
Information
• Identify High Risk Wa
• ConductWaste
•^•••l Management Risk
• L^liAssessment
_
Establishment 1
• Identify and Prioritize \
National Program Areas \
• Define EPA Parnerships and \
Stakeholder Roles \
• Conduct Strategic Planning N
Needs of Program Maj
Resources and Budget
• Establish Program Direction -^ —
• Support Other Government
Activities on Wastes
ste 1
Program
Standards
sl« TV i i
Development
RCRA Hazardous Waste |
Program Activities 1
Activities
Mechanisms . Respond to Information
• Maintain Catalog of Requests
Information Definitions
Exhibit 3-1. Key Activities and Sub-Activities of the EPA Hazardous Waste Program Used to Identify Program Areas
3-4
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3.3.2 High Level Categories of Information Needs
Headquarters and regional staff participated in an assessment to identify the information needs
of the EPA hazardous waste program. The identification of information needs is the second
step in the process of interrelating program activities and information needs to identify
Program Areas. Section 3.3.3 provides detail on this process.
In a series of facilitated sessions (described in Chapter 2), EPA managers and headquarters
and regional staff identified 65 strategic information needs, as noted in the introduction to this
chapter. These needs were grouped into eight high-level information categories to assist hi the
identification of Program Areas (see Section 3.3.3). It is important to note that at this point of
the EPA hazardous waste program ISP, the analysis of information is most appropriately
performed at the categorical level. In subsequent phases, EPA will identify the specific
information needs hi considerably greater detail to assist in defining particular data elements.
The 8 high-level information categories and 65 strategic information needs are listed in Exhibit
3-2 and described hi Appendix G.
The results of the information needs assessment indicate that there are many information needs
of the RCRA community and that everyone believes his or her information needs are
important. These needs range from facility-specific to program-wide information. The regions
and headquarters identified information needs in all program areas, although the frequency and
use of those needs varied. The results also tend to reflect the fact that EPA, especially the
regions, still requires information to support program implementation activities, even though
parts of the Agency are moving their focus away from direct implementation and toward
program evaluation and assistance. Although EPA managers and staff are working toward the
goal of performing less direct implementation and more evaluation, they acknowledge that in
the near term, information is still needed to support the regions' implementation role. This
role will continue to drive EPA to request information specific to facility, waste, and program
implementation. As EPA continues to move toward an evaluation role, it is unclear as to
what, if any, reductions hi information requirements will be realized if EPA regions remain in
an implementation role, at least partially.
The information needs assessment also highlights the tension existing between the goal of
achieving significant burden reduction and requirements for facility-specific information (not
related to regional implementation needs). It is important to remember that the information
needs identified were deemed necessary to meet the ISP goals, strategies, and activities of the
EPA hazardous waste program (i.e., program implementation, program development, and
program evaluation) and not to satisfy other Agency priorities. Despite burden reduction
efforts, there does not appear to be a reduction hi information needs. These issues will be
reviewed further during the Program Area Analysis, the next phase of the WIN project.
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High Level
Information
Category
Facility Identification and
Business Operations (1000
Series)
Waste Generation,
Composition, and
Management (2000 Series)
Facility RCRA
Implementation Activities
(3000 Series)
Facility and Constituent
Risk Analyses (4000
Series)
Strategic Information Needs
1100 Specific Lists of Facilities
1200 Name/Address and Location
1300 Regulatory Identification Number
1400 Owner/Operator Identification
1500 Industrial Sectors and Production
1600 Facility and Program Size
1700 Economic Profile
1800 Facility Waste Management Activities
1900 Commercial Waste Handler Status
2100 Waste Identification Codes
2200 Waste Types and Constituents
2300 Waste Generation Processes
2400 Waste Quantities Handled On-site
2500 Off-Site Shipments of Wastes
2600 Pollution Prevention Achievements
2700 Wastes not under Subtitle C
2800 Capacity Analyses
2900 Management Unit Description and
Status
3100 Notification Status
3200 Permit Activities
3300 Enforcement Activities
3400 Compliance Activities
3500 Remediation/Stabilization Activities
3600 Performance Standards and Variances
4100 Environmental Site Characteristics
4200 Population Exposure and
Environmental Justice
4300 Multimedia Releases and Monitoring
4400 . Constituent Toxicity and
Characteristics Data
4500 Fate and Transport Model
4600 Testing and Performance Data
4700 Remediation Risk Analyses
4800 Regulatory Risk Analyses
4900 Permit and Compliance Risk Analyses
Exhibit 3-2. Overview of the EPA Hazardous Waste Program Strategic Information Needs
Grouped into Eight High-Level Categories (numbers represent sub-category denominations used
in this assessment)
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High Level Information
Category
Strategic Information Needs
Program Operations, Plans, and
Evaluation Information (5000
Series)
Customer Service and
Stakeholder Interactions (6000
Series)
Information Systems, Access,
and Outreach (7000 Series)
Legal and Policy Documents
(8000 Series)
5100 Environmental Indicators
5200 National Program Goals and Plans
5300 National Program Performance Tracking
5400 Authorization and Delegations Status
5500 Quality Assurance Data and Plans
5600 Administrative Resources
5700 Grants and Contract Management
5800 Program Implementation Costs to Stakeholders
6100 Stakeholder Identification and Resources
6200 Roles and Responsibilities
6300 Stakeholder Priorities, Perceptions, and Needs
(Feedback)
6400 Public Inquiries and Responses
6500 Stakeholder Participation Activities
6600 Burden Reduction Success Information
6700 Voluntary and Innovative Programs
6800 Technical Compliance Assistance Needs
7100 Core Data Elements and Definitions
7200 National Information Systems
7300 Local and Manual Information Systems
7400 Information Technology Resources
7500 Technical Experts and Peer Review Access
7700 Public Access
7800 Technical Outreach and Training Needs
8100 Regulatory and Policy Flexibility Analyses
8200 Federal Statutes and Authorities
8300 Federal Regulations
8400 Regulatory Support Documents
8500 Federal Policy and Guidance
8600 Court Decisions and Regulatory Litigations
8700 Congressional or Executive Mandates
8800 Other Agency Regulations and Policy
8900 International Agreements and Law
Exhibit 3-2. Overview of the EPA Hazardous Waste Program Strategic Information Needs
Grouped into Eight High-Level Categories (numbers represent sub-category denominations used
in this assessment) (continued)
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3.3.3 Identification of Program Areas
A Program Area represents a set of activities that create and/or share a common set of
information. By identifying Program Areas for information management purposes,
organizations and activities that create and use the same information can be considered
together under one Program Area. Program Area identification facilitates the development of
a more integrated set of systems and avoids the problems associated with independent efforts
to solve common information management problems. (Appendix H provides a detailed
explanation of the development of the Program Areas based on the program activities and
information needs. The appendix also explains how the Information Engineering Facility™
CASE Tool was used as an aid in developing the Program Areas.)
Using the process described above, the followhlg Program Areas for the EPA hazardous waste
program were identified:
• Program Development.
• Program Evaluation.
• Program Implementation.
• Program Implementation Support.
• Information Sharing.
• Program Management.
• Studies and Research.
To capture this process, Exhibit 3-3 displays the program activities (shown in boxes) and
information groups (shown hi ovals) that are interrelated to form each Program Area.
3-8
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Information Sharing
Provide Access to Program Information
Assess Program Technology Needs
Develop Mechanisms for Information Collection
Integrate Information
Provide Mechanisms for Disseminating Information
implement Data Security Mechanisms
Maintain Catalog of Information Definitions
(•^ Information Technologies^)
Program Implementation
Identify Universe of Regulated Entities
Implement Corrective Action
Implement Permitting Program
Implement Waste Minimization Program
Monitor Waste Management Activity
Implement Compliance Monitoring and Enforcement
Stakeholder.
Geographic Location
Handfer
Waste Mgt Activity
Corrective Action
Permit Activity \
Compliance Activity )
Site Characteristics • Enforcement Activity/
Program Management
Identify and Prioritize National Program Areas
Define EPA Partnerships and Stakeholder Roles
Conduct Strategic Planning
Assess Strategic Information Needs of Program
Prioritize and Track Program Resources and Budget
Establish Program Direction
Plan Implementation Programs and Resources
Authorize States/Tribal Programs
C
Programs
Program Plan
Program Cost
Program Resource
Program Development
Develop Regulations
Develop Non-Regulatory Approaches
Cr Regulations
|_
_ Policy and Guidance
Exhibit 3-3. Overview of the EPA Hazardous Waste Program Areas
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Hazardous Waste
Program Areas
(
Program Evaluation
Establish National Environmental Baseline and Goals
Establish Environmental Performance Measurements
Establish Program Performance Measurements
Evaluate Environmental Progress
Conduct Audit of Headquarters, Regional, and State Programs
Evaluate Performance of Headquarters, Regional, and State
Program Activities
Identify Program Improvements
C« Environmental Performance Measurement • Program Evaluation^
• Program Performance Measurement ^
)
Program implementation Support
Support Other Government Activities on Wastes
Support Legal Defense of Regulations, Policy and
Guidance
Coordinate Implementation Approach
Provide Guidance, Training, and Technical Assistance
Solicit Feedback
Establish Internal/External Program Communication
Conduct Stakeholder Outreach Activities
Respond to Information Requests
(•^Stakeholder Feedback* Information Request • Training' Technical Assistant)
Studies and Research
Analyze Industrial Waste Information
Identify High-Risk Wastes
Conduct Waste Management Risk Assessment
Conduct Waste Characterization, Waste Management,
and Economic Studies
Conduct Impact Assessment
Develop Methods and Technologies
C« Method and Technology • Risk Management^
• Research • Waste ^}
Exhibit 3-3. Overview of the EPA Hazardous Waste Program Areas (continued)
3-11
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4.0 EPA HAZARDOUS WASTE PROGRAM CURRENT SYSTEMS ASSESSMENT
The Current Systems Assessment was conducted to identify the current information sources
used by OSW, OECA, and regional staff to support the hazardous waste program activities
and information needs identified in Chapter 3 of this ISP. Additional objectives of the
assessment were to determine how easily the users can access the information in the identified
sources and to discover user perceptions of information reliability for each of the identified
sources.
This chapter focuses on the following areas:
• Key questions answered by this chapter.
• Key findings of the Current Systems Assessment.
• Discussion of the adequacy of the current information sources in supplying EPA's
strategic information needs.
• Discussion of the major sources that supply data to the EPA hazardous waste program,
including a description of the reliability and accessibility of these sources.
Appendix I provides a detailed discussion of the methods used to evaluate current systems and
a discussion of current systems that support each hazardous waste program area, as well as a
catalogue of current information sources identified for each information need listed hi Chapter
3.
[Note: Chapter 6 presents a summary of the key systems support issues that emerge from this
assessment].
4.1 KEY QUESTIONS
What are the major sources of information currently used to support the EPA hazardous waste
program?
What are the major gaps and weaknesses for hazardous waste information support?
4.2 KEY FINDINGS
The key findings of the Current Systems Assessment are as follows:
• More than 50 automated and non-automated information sources are currently
maintained. Taken as a whole, these sources address the majority of information
needed about the regulatory process and hazardous waste activity. Many of these
systems are currently available to program staff via the Agency's mainframe, the
Agency's value added backbone services (VABS), or the Internet (See Exhibit 4-2).
4-1
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• Most hazardous waste information sources lack data to support multi-media and
industry sector-based assessment of the environmental results for hazardous waste
regulation.
• The need to evaluate and combine hazardous waste, scientific, and population and
industry demographic information from diverse sources will increase as EPA
incorporates multi-media, industry sector, and environmental risk-based approaches in
hazardous waste program management. Automated data systems will need to address
the requirement to link or combine their information with information obtained from
many diverse sources.
• Much of the information supporting the hazardous waste program exists in documents
ranging from regulatory policy and guidance to published studies and research. To
support broad accessibility to text-based information, EPA should maintain an easily
accessed and searchable archive of important documents that support the hazardous
waste program.
• Most national data systems are considered difficult to access.
• Most national data systems are considered to have information of medium reliability,
which means that the information requires some verification of validation before use.
• Data consistency and reliability issues must be continuously addressed for any
information system that acquires its information from diverse suppliers across EPA
regions, states, and industry.
4.3 DISCUSSION
EPA identified the types of current systems supporting the EPA hazardous waste program.
The current systems were identified through a series of interviews with EPA headquarters
(OSW and OECA) and through surveys of Regions 3, 9, and 10. The headquarters interviews
included staff from all OSW divisions, as well as OECA's Offices of Compliance, Regulatory
Enforcement, and Site Remediation and Enforcement. Although the interviews and surveys
did not cover all the systems supporting the hazardous waste program, they did provide useful
insight as to the general level of current systems supporting the program. The interviews and
surveys focused on the information needs identified in Chapter 3 of this ISP. Program staff
were asked to identify the source(s), if any, currently used to obtain the identified information
and to rank the accessibility and reliability of the information obtained in terms of high,
medium, and low. The program staff provided a broad range of responses. EPA did not
perform a statistical analyses of the responses. Rather, EPA assigned numerical values to each
of the rankings and averaged the results across participants to assign an overall accessibility
and reliability ranking for each information source. EPA then examined the information needs
for each Program Area and identified die sources of information updated or accessed.
4-2
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The six most frequently used information sources are the Biennial Reporting System (BRS),
Code of Federal Regulations (CFR), Industry Studies Database (ISDB), Integrated Database
for Enforcement Actions (IDEA), Resource Conservation and Recovery Information System
(RCRIS), and Beginning of Year Plans (BYP). Many other information sources are regularly
used by EPA hazardous waste program staff and are maintained by organizations external to
the EPA hazardous waste program, such as the Office of Information Resources Management
(OIRM), Office of Pollution Prevention and Toxics (OPPT), Office of Research and
Development (ORD), other government agencies, and commercial sources. Most EPA staff
interviewed indicated that the majority of their work requires the ad hoc consolidation and
evaluation of information about industry and hazardous waste activity. This information is
most often obtained from a variety of automated and non-automated sources. It is extremely
difficult to link or combine information obtained from the many diverse sources. This
difficulty is considered a key weakness of current systems supporting the hazardous waste
program, preventing EPA from conducting effective multi-media, sector-based, and
environmental risk analysis.
Chapters 2 and 3 of this ISP identify multi-media, industry sector, and environmental risk-
based approaches as the future drivers of the hazardous waste program. Current automated
information systems were designed as specialized systems for tracking programmatic,
regulatory, and hazardous waste activities. These systems either do not address or do not
effectively support the information required to manage and evaluate the hazardous waste
program from these perspectives. The GATEWAY/GIS system was identified as a reliable
source of information for population demographics, but it is difficult to link or combine this
information with data from the other current systems. Because information is largely
unavailable to support assessments based on multi-media and industry sector, EPA, states, and
industry must work together to define the information needed to support these new hazardous
waste program directions.
The new multi-media, industry sector, and environmental risk approaches are, by definition,
holistic approaches that rely on diverse information. Most of the existing automated data
systems were designed from a media-specific perspective to support the specific regulatory
activities and information needs of then- host regulatory program. As a result, there is very
little current systems support for linking or combining information obtained from these
automated data systems. To successfully meet the challenges of these new approaches to
hazardous waste program management, users will need easy access to national data systems,
clear documentation of their information content and limitations, and integrated support for
linking and combining information obtained from a variety of sources.
Many of the staff members interviewed indicated they regularly refer to document archives
that provide the definitive source for information about topics including hazardous waste
program requirements, wastes, treatment standards, and remediation standards. Although
most individuals interviewed had access to the documents they considered critical to their
work, it became apparent that knowledge of, and access to, much of this information was
4-3
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limited to the specific organization or staff that maintained these documents, and not to others
who could use the information if they knew it was available and accessible.
The inaccessibility of automated national data systems is primarily due to the following
factors: most systems reside on the mainframe, which users find difficult or impossible to use;
the information in most systems is complex; and systems and information documentation are
hard to access and understand. To acquire needed information, most users required the
assistance of a technical data systems expert. Accessibility is, therefore, a key weakness of
many national data systems. Future projects must develop effective methods for providing
easy access to national data systems, flexible methods for accessing their information content,
and clear documentation of their information content, its correct usage and limitations.
Most respondents used the expression of medium reliability to describe information requiring
some verification or validation before use. For information content control, mere are two
major types of information sources: those for which content is supplied and maintained by a
small number of users and those for which content is supplied and maintained by large
numbers of users. In general, the information sources maintained by small numbers of users
were considered highly reliable, and those maintained by large numbers of users were
considered only moderately reliable.
The key factor influencing the reliability of hazardous waste information obtained in this
manner is the degree of consistency hi individual interpretation and classification of the real
world hazardous waste activity. Achieving information consistency among many suppliers and
across many organizations is a daunting task. This task becomes even more difficult during
periods of significant change hi information requirements. Future information systems
projects must recognize that consistent human interpretation of hazardous waste activity is the
key to consistent and reliable hazardous waste information. These projects must make every
effort to provide information suppliers with clear and accessible training and guidance to
support consistent interpretation and characterization of hazardous waste activity.
4.4 CURRENT SOURCES OF INFORMATION
Exhibit 4-1 provides a brief description of the information sources identified, their owner,
overall reliability and accessibility rating, and group(s) using the source. The sources listed
are grouped as follows: Agency wide sources, locally available sources, program and
regulatory requirements sources, commercial and other government sources, and science and
engineering sources. The reliability and accessibility rating was on a scale of high (H),
medium (M), low (L), or no opinion/undecided (X). A highly reliable source is one that
provides data that the user accepts and trusts. A source rated low for reliability provides data
that does not represent real world values and must be verified against another source of
4-4
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information. A highly accessible source means that a user can quickly and easily obtain data
directly from the source. A source rated low for accessibility means that an unreasonable level
of effort is required to obtain the data. In addition, Exhibit 4-2 provides a subset of the major
information sources, a description of how the information source can be accessed, and the
person to contact for access.
4-5
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I
Current Data Source
Description
Owner
Reliability
Accessibility
6roup(s) using
the Source
AGENCY INFORMATION SOURCES
Biennial Reporting System
(BRS)
i
Comprehensive Environmental
Response, Compensation and
Liability Information System
(CERCLIS/CERCLIS3)
Contains information on waste generation, management,
management capacity, and minimization information for
RCRA large-quantity generators and for treatment, storage,
and disposal facilities subject to RCRA permitting
requirements. BRS datasets can be accessed via the Internet.
Functions as the Superfund database that contains information
on hazardous waste sites from initial discovery to listing on
the National Priorities List.
EPAHQ:OSW
EPA HQ: Office of
Solid Waste and
Emergency
Response
(OSWER)
(Superfund)
M
M
L
L
Regions 3, 9,10
CIRMD-RCRA
Hotline (H)
CIRMD-Information
Mgmt Branch (I)
EMRAD
HWMMD-Analysis
and Information
Branch (A)
HWMMD-Waste
Treatment Branch (L)
HWMMD-Waste
Minimization Branch
(W)
OECA-Office of
Regulatory
Enforcement (OR)
PSPD-Federal, State,
Tribal Programs
Branch (ST)
HWID
HWMMD-A
PSPD-Corrective
Action Branch (CA)
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program
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Current Data Source
CLU-IN
ENVIROFACTS
Enviro$en$e Bulletin Board
System
EPA Locator
Emergency Response
Notification System (ERNS)
Facility Index System
(FINDS)
GATEWAY/GIS
Integrated Data for
Enforcement Analysis System
(IDEA)
Description
Serves as an information exchange bulletin board system that
provides for the exchange of information on programs
operated by OSWER. These programs include the solid and
hazardous waste program, the underground storage tank
program, emergency preparedness and prevention program,
and the emergency response and remediation program.
Functions as a relational database that integrates data
extracted from five major EPA program systems:
AIRS/AFS, CERCLIS, PCS, RCRIS, and TRIS.
Is an electronic library of regulatory data and educational
information on pollution prevention (P2), technical assistance,
and federal facilities environmental compliance and
enforcement.
Used as a personnel locator. Provides such information as
name, office, and telephone number.
Contains information on specific notifications of releases of
oil and hazardous substances.
Provides basic information about facilities regulated by EPA
and identifies sources of more detailed information.
Provides spatial data, including geographic and demographic
data.
Used as a cross-media enforcement case management tool.
Owner
EPA HQ: OSWER
EPAHQ:OIRM
EPA HQ: ORD,
OECA, DOE, and
DOD
EPAHQ
EPA HQ; OSWER,
OERR, ERD
EPA HQ: OIRM
EPA HQ: OIRM
EPA HQ: OECA
Reliability
X
X
H
H
X
L
H
M
Accessibility
X
L
M
M
X
L
H
L
Group(s) using
the Source
CIRMD-H
CIRMD-H
HWMMD-W
OECA-OR
OECA-OfficeofSite
Remediation
Enforcement (OS)
CIRMD-I
HWMMD-W
PSPD-CA
Regions 3, 10
EMRAD
OECA-Office of
Compliance (OC)
OECA-OR
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
4-7
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Current Data Source
National Enforcement
Investigation Center (NEIC)
Permit Compliance System
(PCS)
Records of Decision System
(RODS)
Resource Conservation and
Recovery Information System
(RCRIS)
Toxic Release Inventory
System (TRIS)
Description
Provides facility enforcement and hazardous waste
import/export information.
Tracks permit, compliance, and enforcement status of
NPDES facilities. Keeps records on approximately 75,000
water discharge permit holders including inventory,
discharge limit, discharge monitoring, and non-compliance
information.
Tracks site cleanups under the Superfund program and to
justify the type of treatment chosen at each site.
Also stores information on the technologies being used to
clean up sites.
Contains information on handler, permitting, corrective
action, and compliance activities for RCRA hazardous waste
handlers. RCRIS datasets can be accessed via the Internet.
Tracks information on facility and substance identification,
environmental chemical release, offsite waste transfer, and
waste treatment/minimization information. Tracks amounts
on more than 300 listed toxic chemicals that facilities release
directly to air, water, or land or transport (transfer) offsite.
Owner
NEIC
EPA HQ: Office of
Water (OW)/OECA
EPA HQ: OERR
and OSWER
EPAHQ:
OSW/OECA
EPAHQ:OPPT
Reliability
M
X
M
M
L
Accessibility
M
X
L
L
L
Group (s) using
the Source
HWID
HWMMD-A
OECA-OR
OECA-OC
HWMMD-A
PSPD-CA
Regions 3, 9, 10
CIRMD-H,I
HWMMD-A.L
OECA-OC.OR.OS
PSPD-CA
PSPD-Permitting
Branch (PM)
Regions 9, 10
CIRMD-H
HWID
HWMMD-W
OECA-OC, OR
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
4-8
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Current Data Source
Description
Owner
Reliability
Accessibility
Group(s) using
the Source
LOCAL INFORMATION SOURCES
CodeTalk
Corrective Action Instrument
Tracking System (CAITS)
Federal/State/Tribal Programs
Branch Bulletin Board System
(FSTPB-BBS)
Ground Water Information
Tracking System (GRITS)
HWIR Process/Waste DB
INDIANnet
Industry Studies Database
(ISDB)
Functions as an information-sharing network for and about
Native Americans.
Provides a mechanism for tracking corrective action activity.
Contains information on areas, including regulations and
policy.
Contains ground water monitoring data with statistical
capability and RCRA Subtitle D and C site, facility, and
constituent information.
Contains information on waste streams, volumes, quantities,
waste codes, constituents, and concentrations per facility.
Designed to provide information from the federal and other
levels to Native Americans.
Provides facility specific information on waste generating
production processes, the characteristics of wastes, and waste
management units.
Department of
Housing and Urban
Development
(HUD): Office of
Information
Policies and
Systems
EPA Region 3
PSPD-ST
PSPD-ST
EPA HQ: EMRAD
Americans for
Indian Opportunity
Commercial
H
M
M
M
H
H
M
H
L
M
L
H
H
M
PSPD-ST
Region 3
Regions 3, 9
PSPD-CA
EMRAD
PSPD-ST
EMRAD
HWID
HWMMD-A
PSPD-PM
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
4-9
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Current Data Source
OMBUDSMAN
(OMBUDDY)
Remedial Options (REOPT)
RCRIS Quicklook
State Authorization Tracking
System (STATS)
Description
Tracks information on anonymous phone calls received by
type, area, and program.
Contains information on remedial actions technology and
constituent and environmental regulations.
Provides a user-friendly interface for reviewing information
extracted from RCRIS.
Contains information on which states are authorized for what
activities.
Owner
EPA-OSWER-
OMBTJDSMAN
Department of
Energy (DOE)
EPA Region 9
EPA HQ: OSW
(PSPD)
Reliability
X
H
M
H
Accessibility
L
H
M
L
Group (s) using
the Source
CIRMD-H
PSPD-CA
Region 9
Region 9
PSPD-ST
PROGRAM POLICY AND REGULATORY INFORMATION SOURCES
Beginning Year Plans (BYPs)
Codes of Federal Regulations
(CFR)
Enforcement Docket
(DOCKET)
Documents regional activities for the coming fiscal year
based on the RCRA Implementation Plan (RIP).
Listings of the general and permanent rules published in the
Federal Register (FR) by the executive departments and
agencies of the federal government.
Contains information related to civil judicial enforcement
activity, including case information, facility information, and
defendant information.
EPA HQ: OSW
(PSPD)
Office of the
Federal Register
National Archives
and Records
Administration
EPA HQ: OECA
M
H
M
M
H
L
OECA-OC.OS
PSPD-PM.ST
Regions 3, 9, 10
CffiMD-H,I
EMRAD
HWID
HWMMD-A.L.W
OECA-OC,OR,OS
PSPD-CA,PM,ST
OECA-OC.OS
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
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Current Data Source
Federal Register Notices
RCRA Permit Policy
Compendium (PPC)
Pollution Prevention
Information Center (PPIC)
RCRA Docket
RCRA Docket System
(RCRADS-SEEK)
Description
Contains information on regulations and proposed
regulations.
Functions as a reference for regional and state permit writers
on permitting policies and procedures.
Provides industry fact sheets and other general pollution
prevention information.
Provides references on rulemakings that deal with RCRA.
Stores, retrieves, and displays key information about OSW
regulatory documents and publications at the RCRA
Information Center.
Owner
EPA HQ:
OSW/OECA
EPA HQ: OSW
(PSPD)
Pollution
Prevention Division
(PPD)
EPA HQ: OSW
(CSB)
EPA HQ: OSW
(CSB)
Reliability
H
M
X
H
H
Accessibility
H
M
L
L
H
Group(s) using
the Source
Regions 3, 9, 10
CIRMD-H,!
HWMMD-A.L.W
OECA-OC,OR,OS
PSPD-CA.PM.ST
Region 9
CIRMD-H
HWMMD-L
OECA-OC
PSPD-CA,PM,ST
HWMMD-W
CIRMD-H
HWID
HWMMD-L
OECA-OC
PSPD-PM.ST
CIRMD-RCRA
Docket (D)
COMMERCIAL AND OTHER GOVERNMENT INFORMATION SOURCES
Dun and Bradstreet
Provides information on companies, such as economic
profile, business size, and annual reports.
Dun and Bradstreet
M
M
Regions 9, 10
EMRAD
OECA-OC.OR
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
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Current Data Source
Greenwire
LEXIS
National Technical
Information Service
RTKNet
Description
Serves as a source of current environmental news.
Is a full-text legal information service.
Provides access to software, datafiles, and databases
produced by federal agencies.
Is the Right to Know computer network bulletin board
system.
Owner
.EPAHQ
Reed Elsevier Inc.
U.S. Department of
Commerce
UNISON Institute
and OMB Watch
Reliability
H
H
X
X
Accessibility
H
H
L
L
Group(s) using
the Source
OECA-OR
OECA-OR.OS
CIRMD-H
CIRMD-H
SCIENCE AND ENGINEERING INFORMATION SOURCES
Alternative Treatment
Technology Information
Center (ATTIC)
Environmental Monitoring
Methods Index (EMMI)
Health Effects Assessment
Summary Tables (HEAST)
ATTIC is a comprehensive computer database system
providing up-to-date information on innovative treatment
technologies and access to other databases to assist in
determining hazardous waste clean-up alternatives.
Contains information on 2,600 regulated chemical
substances, which are identified on 50 statutorily mandated
and office-based lists and more than 900 analytical methods.
Summarizes toxic effects of individual chemicals and also
provides unverified health benchmarks for certain
carcinogens and non-carcinogens.
EPA Cincinnati:
National Risk
Management
Research
Laboratory
(NRMRL)
OW Regulations
and Standards,
Office of Science
and Technology
EPA in Cincinnati:
Office of Research
and Development
(ORD), Office of
Health and
Environmental
Assessment
M
M
H
M
M
M
CIRMD-H
PSPD-CA
EMRAD
CIRMD-H
EMRAD
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
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Current Data Source
Integrated Risk Information
System (IRIS)
Description
Provides detailed information on chemicals and EPA
consensus opinion on potential chronic human health effects
related to chemical hazard identification and dose-response
assessment.
Owner
EPA in Cincinnati:
ORD, Office of
Health and
Environmental
Assessment
Reliability
M
Accessibility
L
Group(s) using
the Source
CIRMD-H
EMRAD
HWID
PSPD-CA
*In terms of reliability and accessibility, H means high, M means medium, L means low, and X signifies no opinion.
Exhibit 4-1. Overview of Current Systems Used to Support the EPA Hazardous Waste Program (continued)
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RCRIS/BRS Data Source
roEA-WIN
RTK-NET
ENVIROFACTS
Environmental Factors CD-ROM (NTIS)
Contact
1-888-EPA-IDEA
(202) 234-8494
None provided
Fax Back
(703) 487-4140 Code = 8679
Web URL (if applicable)
Available from EPA Wide Area Network (VABS)
www.rtk.net
www.epa.gov/enviro/html/ef_home.html
www.ntis.gov
Exhibit 4-2. Some Sources for RCRIS and BRS Data
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5.0 POTENTIAL TECHNOLOGIES AND EVALUATION CONSIDERATIONS
To identify the information management requirements of each Program Area, EPA and the states
must integrate their information strategy efforts and analyze the specific information
management requirements,of each program area. The state and EPA PAA projects will define
the information management requirements, roles, and responsibilities of the states and EPA
organizations. Each PAA effort will document such information requirements such as: the types
of data, the quantity of data, who creates the data, and how data are shared or transferred among
organizations and users. Specific information technologies cannot be chosen or properly
evaluated at this stage because they must be evaluated within the context of the requirements
defined for each Program Area.
This chapter describes some of the technologies likely to be considered based on EPA's current
knowledge of the hazardous waste program and proposes criteria that may be useful when
evaluating the suitability of these and other future technologies. The primary sections hi the
chapter address these topics:
This chapter addresses the following:
• Key questions answered by this chapter.
• Key findings of this chapter.
• General criteria that EPA should consider when evaluating technologies.
5.1 KEY QUESTIONS
What are some information technologies that can potentially improve EPA's ability to satisfy
its hazardous waste information needs?
What characteristics should be considered when evaluating technologies?
5.2 KEY FINDINGS
• Hazardous waste information technologies will need to accommodate the broad range
of technology and information requirements of the hazardous waste program
stakeholders: EPA, states, tribes, industry, and the public.
• Hazardous waste information technologies will need to be user friendly and support
broad sharing and accessibility of information.
• Hazardous waste information technologies will need to support a variety of automated
information collection methods.
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• Hazardous waste information technologies will need to facilitate the integration of
information from many sources.
• Any information technologies being considered for the EPA hazardous waste program
will need to be evaluated against a set of criteria that reflects user requirements.
5.3 DISCUSSION
Many of the information needs identified for the hazardous waste program are supplied either
directly or indirectly by the implementers of the hazardous waste program (states, tribes, and
EPA regions). In fact, information for a specific hazardous facility can be supplied by the
facility, the state environmental agency implementing a portion of the hazardous waste program,
and the EPA region implementing a portion of the program.
To effectively and efficiently integrate and consolidate information for access by all
stakeholders, the hazardous waste information technologies will need to support the collection of
information from a variety of stakeholders who use a wide range of technologies.
Specific technology choices cannot be made without evaluating appropriate technologies based
on the particular requirements defined for each Program Area. Each PAA effort will need to
document the specific information management requirements that must be satisfied by the chosen
technologies. As a result, EPA determined that a detailed technology assessment could only be
conducted after PAA projects have identified their information management requirements.
5.3.1 Potential Technologies
Based on historical experience in hazardous waste information management, EPA compiled the
following list of technologies mat may potentially meet some needs for hazardous waste
information management:
• Automated telephone registration (ATR),
• Machine readable forms technologies.
• Document faxback system.
• CD-ROM technologies.
• Electronic reporting software (ERS) and on-line reporting (OLR).
• Electronic data interchange (EDI).
• Electronic bulletin board systems (EBBS).
• Relational data base management system (RDBMS).
• Internet/Intranet Web Servers and Hypertext Markup Language (HTML).
• Geographic information systems (GIS).
• Data warehousing.
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The selected technologies address the major information management activities of information
collection, information integration, and information dissemination.
Again, this is a preliminary list of technologies that would need to be assessed within the context
of the specific information support requirements developed by EPA and hazardous waste
program stakeholders during PAA. It is important that any technology or suite of technologies
be thoroughly researched and verified with the RCRA stakeholders prior to selection. EPA
realizes that additional technologies may need to be added to the list. The Agency also realizes
that some of these technologies are already in use and support a specific niche hi certain Program
Areas.
Automated Telephone Registration (ATR)
ATR systems guide users through a fixed set of voice and telephone keypad response choices,
enabling the user to report and/or request basic information. A respondent could call a
telephone number and, using the key pad on the phone, type in alpha and numeric responses,
which would then be entered into and stored in a database. This technology would support only
a very limited or basic data collection effort.
Machine Readable Forms Technologies
Regulated facilities could report information using a form-driven submission process.
Although the submission itself is not electronic, the data on the forms can be entered
automatically into a database by sending the forms through an optical character recognition
(OCR) reader. An OCR reader performs the following tasks:
• An OCR device, connected to a computer, electronically scans text and numeric
information from a hard copy document.
• Interpretation software converts each character into an electronic format,
• A recording program then identifies the fixed location of the character on the paper
form and associates it with a particular data field. Edits can be programmed into the
system to verify data completeness and validity on the hard copy form.
Document Faxback System
Faxback technology is a method that allows information to be disseminated via fax to any
stakeholder requesting information. A requestor can call a designated telephone number that
will provide access to a RCRA faxback system. By following a few steps, the caller could
request RCRA information (e.g., reports) that will then be sent back to his/her fax machine or
modem. Callers without access to a fax machine or fax modem cannot use this technology.
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CD-ROM Technologies
A CD-ROM publication is an evolved version of a hard copy publication. More and more
documents and data sources are being published on CD-ROM because of its capability to store
large volumes of information and to support retrieval and analysis of fielded data. A very
large publication, one that is too large to fit on a single CD-ROM, could require multiple CDS
(e.g., the publication could be divided into sections so that each CD-ROM in the set contains
data from one or two states).
Relevant publications could be copied periodically to CD-ROM and the data organized so that
any standard database application could be used to query and analyze the documentation. The
CD-ROM could be made available to the public through the National Technical Information
Service or through the Emergency Planning and Community Right-to-Know Document
Distribution Center.
Electronic Reporting Software (ERS) and On-line Reporting (OLR)
ERS and OLR allow reporters to compile their reports using form-driven interactive software.
For both of these technologies, organizations or individuals enter information assimilated from
existing records using interactive software that supports context sensitive help, response
validation, report viewing, and report evaluation. The two technologies differ in two areas.
ERS runs on the reporter's local computer, and OLR software runs on a remote computer that
must be accessed via a telecommunications connection. In addition, ERS reports must be
transmitted to the collector using telecommunications access or on magnetic media, and OLR
reports are functionally instantaneous. Cutting edge technologies, such as Sun Microsystems'
Java scripting, also support hybrid variations of ERS and OLR.
Electronic Data Interchange (EDI)
EDI is a set of formal technical specifications and procedures for the electronic transmission of
business transactions. EDI allows reporting directly from a reporter's existing data system.
Information is transmitted to the collector via a commercial network. The EDI foundation is
the use of standardized transaction specifications that can be processed using commercially
available EDI translation software over commercial EDI networks.
The following must be achieved to implement EDI:
• Specifications for the EDI transaction set will need to be developed to satisfy the
information reporting requirements.
• The transaction set specifications will need to be submitted to a national EDI standards
committee that certifies compliance and publishes the specifications for use by
commercial EDI software developers.
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• Participating reporters will need to purchase EDI translation software, develop
software to extract the transaction information from their database and map it to the
EDI translator database, and contract for transaction clearing services through a
commercial carrier.
• Agencies accepting EDI transactions will need to purchase EDI translation software,
develop software to extract the information from the EDI translator and map it to the
agency database, and contract for transaction clearing services through a commercial
carrier.
Electronic Bulletin Board Systems (EBBS)
The EBBS is a technical option that allows information to be disseminated to or from the
desktop electronically. This technology eliminates the need to transfer disks or other media
back and forth in order to integrate information into a database system.
An EBBS typically resides on a centralized PC that can be accessed by a variety of users.
Access to an EBBS is relatively easy and requires limited hardware and software. An EBBS
can be made available through a centralized toll or toll-free number to a single or multi-user
line connected to the EBBS PC. The number of simultaneous user calls is limited to the
number of available telephone lines. An EPA EBBS (e.g., Technology Transfer Network,
Enviro$ense) typically has multiple telephone lines.
The EBBS could be set up to allow users to upload information, which could be incorporated
into a database. The EBBS could then act as an OLR system that would allow users to view,
or request for download, information stored in the database.
Relational Data Base Management System (RDBMS)
RDBMS is a database organization scheme that treats files as tables of data in which the rows
represent records and the columns represent fields. In a RDBMS, some data items in one type
of record can refer to records of a different type. Relational databases give the user the
flexibility to link information stored in many separate files and to interchange and cross-
reference information between two different record types. RDBMS applications provide an
integrated suite of software applications used to develop database systems that manipulate data
organized in cross-referenced tables. Most full-scale RDBMS applications provide tools to
develop table structures, data maintenance applications, ad-hoc queries, and standard reports.
RDBMS technology, the most widely used and understood database technology, supports
flexible integration and dissemination of RCRA information. EPA's Enterprise Technology
Services Division is endorsing RDBMS technology and the use of RDBMS packages, such as
ORACLE.
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Internet/Intranet Web Servers and Hypertext Markup Language
The Internet is an interconnected network of computers that provides an infrastructure to
enable millions of people to communicate and share information electronically. Individuals
can access the Internet hi various ways:
• An on-line service (e.g., America Online™, CompuServe™, Prodigy™) provides
Internet access to users, hi addition to providing other services. On-line services
charge users for Internet access based on usage, much like telephone long-distance
calls.
• Some local providers sell unlimited Internet access to users for a single monthly fee.
• Many companies, government agencies, and other organizations have established
networks with Internet connections. Employees and other individuals with access to
these networks need only a Web browser (software that supports browsing information
on the Internet) and authorized access to the Internet.
An EPA Internet server could also house static RCRA information (e.g., documentation,
images, data, downloadable files). Static information is the most common form of data on the
Internet today.
HTML offers an electronic publishing standard that allows electronic text and graphic images
to be uniformly accessed and displayed by a broad range of commercially available browser
applications. HTML integrates information display standards and dynamic linking to other
files referenced within a document. HTML browsers request HTML documents from the Web
servers, which transfer the requested documents and pass information requests to other
applications accessible from the server.
Web server technology provides a communications gateway that services browser requests for
HTML documents. The Web server can provide interactive access to electronic text, images,
structured databases, and software applications. In addition, the Web server can deliver access
to cross-referenced information from any computer connected to it via closed networks or the
Internet.
Natural language search engines provide efficient access to the diverse information available
on the Web. A natural language search engine allows users to create English-like queries to
identify and access all information available on the server for a user-specified topic(s).
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Geographic Information Systems (GIS)
GIS provides access to structured data organized by physical location expressed in latitude,
longitude, and elevation. GIS technology allows diverse data from a variety of sources to be
dynamically grouped and/or aggregated based on the shared locational context of the
information. Given the necessary locational information, GIS can dynamically group
information for any conceivable three-dimensional boundary, such as a hazardous waste
management unit, corrective action area, facility, river, lake, wetland, or state. GIS easily
accommodates information access and presentation using graphically displayed geographic
maps.
Data Warehousing
A data warehouse is a managed database that consolidates information from disparate
databases, keeps the information current, and structures it for decision-support queries. Data
warehouses support the shift from application-oriented data (e.g., data designed to support
application processing) to decision-support data (e.g., data designed to aid in decision
making). Data warehouses are generally created to consolidate application-oriented data from
different legacy systems. The data from these systems are probably in different formats and
encodings. New data are always appended to the database, rather than replaced, and the
database continually absorbs new data, integrating the new with the previous data.
5.3.2 Evaluation Considerations
User requirements must be taken into consideration when evaluating any set of technologies
for a particular information management problem. For assessment purposes, these
requirements can be expressed as evaluation criteria. EPA has developed an initial list of
general evaluation criteria that can be used to compare and contrast the advantages and
disadvantages of specific technologies:
• Reliability.
• Accessibility.
Cost.
• Flexibility.
• Portability.
Useability.
Infrastructure compatibility.
Telecommunications requirement.
Processing requirement.
System security.
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• Electronic media information access.
• Scalability.
• Historical record keeping.
Each criterion is described below.
Reliability
Technologies should have market stability in terms of a mature product, high level of user
support, and a high level of market penetration. This criterion is important because
implementation of a stable technology helps to reduce costs in the long run (e.g., a stable pool
of programming resources exists to provide support, manufacturer will continue to provide
support). Trade journals and/or other sources, such as Internet, can be examined for
information on the various technologies. The technologies can be ranked as follows:
High:
• Medium:
• Low:
Accessibility
All sources give a positive review (e.g., there is a consensus that the
product is stable, offers a high degree of user support and
documentation, and has high market penetration).
Some sources give a positive review.
One or no source gives a positive review.
The technology should be easily available to the Agency and, where applicable, states, the
regulated community, and the public. For EPA, the hardware, software, and
telecommunications components should be accessible in terms of their availability on the
General Services Administration (GSA) schedule and the support they are given by the
Enterprise Technology Services Division (ETSD). In addition, the hardware and software
should not be cost prohibitive. The rankings for this criteria are as follows:
• High: The technology is currently available. The technical solution for
delivering information is available through existing EPA hardware and
software contracts.
• Medium: The technology is not currently available through existing EPA hardware
and software contracts, but there are plans to make it available.
• Low: The technology is not available through existing EPA hardware and
software contracts, and there are no plans in place to make it available.
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Cost
Several costs are associated with each potential technical option, which should not be ranked
(high/medium/low) like the other criteria. The major expenditures can be divided into four
cost categories:
• Maintenance Cost: The cost of keeping a system running at a uniform level of
operation.
Operational Cost:
Transition Cost:
The day-to-day cost of running the system. Each technical option
will be evaluated for operational cost.
The expense of converting from an existing system (e.g., RCRIS)
to a new system that conforms to the technical option being
reviewed. Transition costs include data conversion from old
systems, installation, parallel operations support, and user
training.
• Development Cost: The initial capital cost for software programming and equipment
purchases necessary to deliver full scale implementation of the
technology.
Cost should be evaluated as a relative factor (e.g., compare costs of the various options).
Flexibility
Technical options should be flexible enough to handle reporting or querying requirements from
different entities, such as states, regions, and headquarters. The rankings are as follows:
High:
• Medium:
• Low:
Portability
Accommodates ad hoc reporting, custom screens, new business needs
(new fields or calculations).
Accommodates some flexibility for the user.
No flexibility. User can only access the query or reporting capabilities
built into the system.
Software products (i.e., either commercially available or developed by EPA) should be useable
on many different computing platforms with many different operating systems (e.g., UNIX
and MS DOS based systems). This criterion is important because it takes into account the
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diverse hardware and software capabilities of EPA, the states, and the regulated community.
The rankings are as follows:
High:
• Medium:
• Low:
Useability
Portable to all major platforms (e.g., IBM PC, UNIX workstations and
servers [Data General and SUN], IBM Mainframe).
Portable to more than one major platform.
Only useable on one major platform and usually considered proprietary.
This criterion examines the extent to which users can easily access and work with the
technology. For example, software products should be available on the user's desktop with a
single, simple user interface, such as Graphical User Interface (GUI). Similar to the flexibility
criterion, a high ranking here indicates that the technology solution is easy to use. The
rankings are as follows:
• High: The technology is very easy to use and is available on the desktop via a
common interface to the information (e.g., GUI).
• Medium: The technology is moderately easy to use and may have more than one
interface to the information.
• Low: The technology is difficult to use, is not available on the desktop, and
several interfaces are required for access to the information.
Infrastructure Compatibility
This criterion looks at how compatible the system will be to the way states, regions, and
headquarters do business. The rankings for this criterion are as follows:
• High: Completely compatible with existing needs.
• Medium: Meets most needs.
• Low: Not compatible with the way business is currently conducted.
Telecommunications Requirement
This criterion examines the types of telecommunication requirements (e.g., hardware,
software) needed to support a technology solution. The criterion is examined because it
provides another type of indicator of the resources needed to support a chosen technology.
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The current EPA and state telecommunication structure should be able to handle the
technology and should allow for expanding technology needs. The rankings are as follows:
• High: Less than 56KB capacity required.
• Medium: Less than Tl capacity but greater than 56KB required.
• Low: Tl line and high performance local area network (LAN) required.
Processing Requirement
The computing platforms should be adequate for the processing load. Poor or inadequate
computers will limit system response. If there is more than one computational platform hi the
system, the heaviest processing should take place on the most powerful platform when
possible. The rankings for this criterion follow:
High:
• Medium:
• Low:
System Security
Low end workstation or PC.
Server.
High end server or mainframe.
To ensure that users can or cannot access or alter sensitive or otherwise restricted information,
system security needs to be implemented. The technology should allow or limit access to
information by category or user at the database, record, or field levels. The following
rankings apply to this criterion:
• High: The technology is mature and has very robust mechanisms to enforce
security (e.g., Resource Access Control Facility on an IBM mainframe).
• Medium: The technology is moderately robust and mature (e.g., Internet
firewalls).
• Low: The technology is not mature or robust and is very limited (e.g., passing
information via diskette).
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Electronic Media Information Access
The technical option should allow for access to other database systems (e.g., Facility Index
System [FINDS], ENVIROFACTS). This criterion addresses EPA's requirement to identify
technologies that facilitate the integration of information from the various Agency and other
relevant information sources. The rankings for this criterion are as follows:
High:
• Medium:
• Low:
Scalability
The technical solution facilitates access to other Agency and commercial
databases. The solution can handle all known media, including audio,
video, images, and text.
The technical solution can provide limited access to other Agency and
commercial databases. It can handle more than one known medium.
The technical solution can handle text only.
It should be possible for an application to operate identically on all platform sizes (e.g., PC,
mainframe, UNIX workstation). This criterion can be ranked as follows:
High:
Operates on all platforms (e.g., PC, mainframe, UNIX server, or
workstation).
• Medium: Operates on more than one platform.
• Low: Operates on only one platform.
Historical Record Keeping
Technical options should provide support for the retrieval of historical information. This
criterion addresses EPA's evolving evaluation role, which requires historical information to
conduct trends analyses. The following rankings are applicable to this criterion:
High:
A large capacity of historical information is available online.
Medium: A medium capacity of historical information is available online. Some
information may need to be retrieved from archival holdings.
Low:
All historical information is archived (or is not available) and difficult to
access. Only current information is available online.
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6.0 PROGRAM AREA PRIORITIZATION AND RECOMMENDATIONS
Chapter 6 outlines how EPA took the key findings of the previous chapters and incorporated
them into an analysis of the seven Program Areas to determine which Program Areas have the
highest strategic importance or need the most immediate improvements. This discussion
provides a prioritization for EPA's next steps. In addition, the chapter analyzes a variety of
short-term projects based on the strategic importance of their respective Program Areas, the
need to enhance the reliability and accessibility of current information systems, and other
external and internal Agency influences currently impacting activity in the EPA RCRA
program. The chapter also reviews options and recommends priority projects.
This chapter addresses the following:
• Key questions answered by this chapter.
• Key findings on overall prioritization of Program Areas and short-term projects.
• Discussion of an overview of Program Area prioritization, an evaluation of each
Program Areas in terms of strategic importance to the EPA hazardous waste program
and its level of current systems support, and an identification of short-term projects
based on Agency program directions and influences.
6.1 KEY QUESTIONS
Which Program Areas need to be analyzed first?
Which Program Areas have the highest strategic importance?
Which Program Areas have information needs requiring the most improvement?
What are the external and internal Agency influences that may affect Program Area priorities?
Do the Program Area priorities change based on these factors?
What short-term projects have been identified in response to external and internal Agency
program influences?
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r
6.2 KEY FINDINGS
• EPA prioritized the Program Areas, using a two-step process. First, EPA evaluated
and ranked each of the Program Areas based on the results of the Program Assessment
and Current Systems Assessment from this ISP. Second, EPA examined the Program
Areas against major external and internal Agency influences (e.g., Key Identifier
Initiative, burden reduction) and evaluated whether the relative rankings of the Program
Areas would change.
• Basing the evaluation on the results of the ISP, the top three Program Area priorities
are 1) Program Implementation, 2) Program Evaluation, and 3) Information Sharing.
Program Evaluation and Information Sharing have equal priority.
• The relative rankings of the top three Program Areas are not changed by the external
and internal Agency program influences. However, the program influences do give
rise to a number of short-term projects. EPA evaluated various ongoing information-
related short-term projects and found they were consistent with the top three Program
Areas and may have some resource implications that will need to be considered.
6.3 DISCUSSION
EPA prioritized the Program Areas, using a two-step process: 1) evaluating the Program Areas
based on the results of the Program Assessment and Current Systems Assessment from this
ISP and 2) evaluating the Program Areas based on other external and internal Agency program
influences. EPA performed this prioritization for two reasons:
• A key premise of the IEM is that one cannot analyze a complex set of interrelated
Program Areas simultaneously and capture all information management requirements in
a systematic way. Instead, one needs to identify the high priority Program Areas and
sequence them so that the results of analyzing one Program Area can be used as input
into the analysis of subsequent Program Areas, thereby leading to an integrated set of
systems.
• Limitations in resources also prevent EPA from analyzing Program Areas
simultaneously. Using existing and projected resources, EPA must identify the most
important Program Areas and analyze them first in the next implementation phase of
this project.
The prioritization of Program Areas based on the first step is discussed directly below in
Sections 6.3.1 (Overview) and 6.3.2 (Detailed Analyses). Each Program Area is presented hi
terms of its strategic importance and level of current systems support. Section 6.3.3
(Evaluation of Program Areas) addresses the second step, evaluating prioritization results of
the first step with respect to major Agency external and internal influences, such as the Key
6-2
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Identifier Initiative, One-stop Reporting Initiative, public access improvements, burden
reduction, and GPRA. This section also discusses the short-term information management
projects initiated as a result of these Agency program influences and shows how they fit into
the overall results of this ISP.
6.3.1 Overview of the Program Area Prioritization Based on Strategic Importance and
Level of Current Systems Support
For the purposes of this analysis, the first factor, strategic importance, is defined as the extent
to which each Program Area addresses the goals and strategies identified hi Chapter 2 and the
way hi which each Program Area fits into the strategic vision of senior RCRA managers. The
activities of a Program Area of high strategic importance create information needed to address
a significant part of the EPA program vision. By addressing a Program Area of high strategic
importance, EPA will work toward delivering information critical to meeting EPA's program
vision.
The second factor that EPA examined for each Program Area is the level of current systems
support. The results were discussed hi the Current Systems Assessment (Chapter 4). Current
systems support is defined as the degree to which the existing network of information sources
delivers the information needed to support the activities and information that comprise the
Program Area. A Program Area that has a high level of current systems support allows users
to implement the activities and access sources that can meet their information needs. A
Program Area that has a low level of current system support suggests the need for
improvement.
Exhibit 6-1 summarizes the results of the evaluation of each Program Area against both the
strategic importance and the level of current systems support. Priority determinations, given
as overall rankings, were made based on a combination of strategic importance and the need
for unproved information and/or sources. For example, a Program Area of high strategic
importance but with limited information systems support (both automated and non-automated)
would be identified as a top priority for further analysis. Conversely, a Program Area that has
high strategic importance but has its information needs generally met would rank as a lower
priority. Similarly, a Program Area of moderate strategic importance that has many unmet
information needs may be ranked relatively high. Section 6.3.2 presents a detailed analysis of
strategic importance and current systems support by Program Area. Appendix I provides
additional detail that explains how EPA assigned numerical point values to the strategic
importance and current systems assessment factors and developed relative rankings of the
Program Areas.
6-3
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Program
Implementation
Program
Evaluation
Information
Sharing^
Program
Development
Program
Management
•Studies and
.Research
Program
Implementation
Support
H
H
H
M
M
L
L
RELIA- ACCESS-
BILITY BIUTY
M
M/L
M
H/M
M
M
M
M/L
L
L
M/L
M
L
M
-a m
m
1
2
2
3
4
5
6
This Program Area is of high strategic importance because it generates the information
needed by many of the other Program Areas.
This Program Area is of equal importance relative to the Program Implementation in its
focus on the fundamental information needed to perform program oversight, whether
measuring program activities or true environmental results. This Program Area lacks
adequate current systems support.
This Program Area provides the technology infrastructure to deliver information to the other
Program Areas. It is also a candidate Program Area for identifying specific short-term
projects that address information access.
This Program Area creates information about regulatory and nonregulatory programs. It
should be addressed after Program Evaluation because of the dependency of information.
This Program Area focuses on strategic planning, budgeting, and partnerships. It does not,
however, address key points relevant to the program vision. The current level of systems
support was more satisfactory than for other Program Areas.
This Program Area strategically is not as high as several other areas because it addresses
only a limited number of management views and strategies. However, it does address a key
issue, which is the need to develop and deliver accurate risk information. The information
from this Program Area is used as input into other Program Areas, such as Program
Development. This Program Area has inadequate current systems support. Hence, some
consideration may be given to placing it higher in the ranking of Program Areas.
This Program Area addresses some aspects of the EPA hazardous waste program strategic
vision. The level of current systems support is more adequate, however, relative to other
Program Areas. This Program Area may be a candidate for certain short-term projects.
Exhibit 6-1. Prioritization of the EPA Hazardous Waste Program Areas
Strategic Importance: (H)igh means that the Program Area contains information that is important to achieving a significant portion of the EPA program vision, i.e., it addresses eight or more goals,
strategies, and executive views. (M)edium means that the Program Area contains information that addresses relatively fewer points of the program vision,; i.e., it address five to seven goals,
strategies, and executive views. (L)ow means that the Program Area contains information that addresses relatively few points of the program vision, i.e., it address four or fewer goals, strategies, and
executive views.
Level of Current Systems Support: (H)igh reliability means the information sources supporting the Program Area provides information that program staff accept and trust. (M)edium reliability
means that program staff need to occasionally verify the information. (L)ow reliability means that the information sources do not provide information that reflects the real world and program staff
must always verify the data. (H) accessibility means that program staff can quickly and easily obtain data directly from the source. (M) accessibility means that program staff either have some time
delays in accessing the information source or have some difficulties in using it. (L)ow accessibility means that program staff must spend an unreasonable level of effort to access and obtain
information from the information sources.
Overall Ranking: (1) means the highest relative ranking based on number of goals, strategies, and executive views addressed and a low level of current systems support, and (6) means the lowest
relative ranking based on a low number of goals, strategies, and executive views addressed and relatively higher level of current systems support. Note that overall ranking was primarily driven by
the number of points assigned for strategic vision and then adjusted, as required, based on level of current systems support.
6-4
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Using the strategic importance and current systems support analyses, EPA ranked priorities
among the Program Areas as follows:
1. Program Implementation
2. Program Evaluation and Information Sharing (tied)
3. Program Development
4. Program Management
5. Studies and Research
6. Program Implementation Support
Comparison ofEPA's Program Areas with State ISP Program Areas
After developing its priority ranking of Program Areas, EPA found it useful to compare the
Agency's priorities against those priorities identified in the state ISP. EPA found that,
although the EPA Program Areas and the state Program Areas are not identical, the top
priorities for both EPA and the state overlap to a large degree. For example, the top state
Program Areas are Universe Identification, Waste Activity Monitoring, Handler Monitoring
and Assistance, and Risk Based Decision Support. The first three Program Areas are subsets
of the first EPA Program Area, Program Implementation. The fourth state Program Area
(Risk Based Decision Support) corresponds with the fifth EPA Program Area, Studies and
Research.
6.3.2 Detailed Analyses of Priority Determinations for the Seven Program Areas
This section presents the detailed analyses that led to the conclusions described in the
preceding section.
Wft
irtementation
(Ranking: 1)
Activities include the following: identify universe of regulated entities, implement
corrective action, implement permitting program, implement waste minimization
program, monitor waste management activity, and implement compliance monitoring and
enforcement.
Groupings of information needs include the following: stakeholder, geographic location,
handler, waste management activity, corrective action, site characteristics, permit
activity, compliance activity, and enforcement activity.
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Strategic Importance — High
Program Implementation is extremely
important because the activities represent
EPA, state, and tribal efforts to ensure the
safe management of hazardous waste to
protect public health and the environment,
which is central to the
mission of the EPA hazardous waste
program. This Program Area generates
most of the information used by EPA
headquarters and regions to evaluate the
progress and effectiveness of the Agency
and the delegated RCRA program. Based on
the evaluation of the program, EPA can
identify and implement program
improvements mat are integral components
of Program Development. Program
Implementation also provides information
for program staff to use when determining
the type of technical assistance and outreach
needed by states and the regulated
community (Program Implementation
Support).
The analysis of Program Implementation
focuses hi part on information management
issues pertaining to the Biennial Reporting
System, Hazardous Waste Manifest, and
Notification. These information systems are
underway — either hi an analysis phase or as
burdens.
Strategic Importance of Program Implementation
• Executive View: EPA continues re-
invention and streamlining activities for the
existing program and makes it simpler and
less burdensome for facilities to show
compliance with environmental regulations
and other performance standards; EPA's
program activities will need to be integrated
with EPA's multi-media approaches to
environmental protection; and the EPA
hazardous waste program will be
incorporating more risk-based decision-
making into all program development,
implementation, and evaluation activities.
• Goals: RCRA is protective of
human health and focuses more on
results than the process; EPA
maintains effective and efficient
partnerships with stakeholders; The
RCRA program integrates into a
multi-media environmental
protection approach, and RCRA
promotes source reduction and
waste minimization.
• Strategies: Program Improvement
and Risk-Based Decision Making.
the subjects of short-term projects currently
a result of recent proposals for reducing reporting
Program Implementation contains a number of critical policy issues related to the role of EPA
and the corresponding issue of generating and reporting facility-specific data. These critical
policy issues must be addressed during the Program Area analysis phase (see Chapter 7).
Attaining the goal of effective, efficient, and fully delegated state and tribal programs will take
time. During this transition phase, EPA (primarily the regions) will continue to be involved in
Program Implementation activities. It is important to recognize that this Program Area
generates some information used to evaluate the program. Moreover, other EPA Program
Areas must access facility-specific information periodically to support the activities associated
with their functions. Therefore, this Program Area continues to be of high strategic
importance.
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Current Systems Support for Program Implementation
Need for Improvement: The key gap in current
systems support for program implementation is the lack
of information supporting multi-media, industry sector,
and location-based evaluation of hazardous waste
activity.
Reliability of information from sources = Medium
Accessibility of information from sources =
Medium/Low
Current Systems Support — Medium to Low
Historically, EPA relied upon facility specific
program implementation information to describe
hazardous waste program status, the regulated
community, and hazardous waste activity. The key
gap in current systems support for Program
Implementation is the lack of information supporting
multi-media, industry sector, and location-based
evaluation of hazardous waste activity. In addition,
while EPA currently is maintaining systems
containing facility-specific information, this ^^^^^^^^^^^^^^^^^^^^
information can be made more accessible to users,
and data quality could be improved. The current
program implementation systems were designed to maintain a history of regulated activity for
each hazardous waste handler. While EPA's initial analysis found a continuing demand for
facility-specific information, the shift in systems support direction will be increasingly to
support program analysis and evaluation based on industry sectors and geographic locations.
To effectively support analysis based on location and address multi-media environmental
concerns, EPA and the states must develop consistent methods for linking information about
hazardous facilities with other location-based information sources. To effectively support
industry sector analysis, EPA and the states must develop consistent methods for classifying
regulated businesses or for linking facility information to other sources of information on
business demographics. A major challenge in this Program Area analysis project will be to
identify the shared implementation information that is needed to support national program
evaluation and the level of detail and update requirements.
(Ranking: Tied for 2)
Activities include the following: establish national environmental baseline and goals,
establish environmental performance measurements, establish program performance
measurements, evaluate environmental progress, conduct audit of headquarters, regional,
and state programs, evaluate performance of headquarters, regional,
and state program activities, and identify program improvements.
Groupings of information needs include the following: environmental performance
measurements, program evaluation, and program performance measurement.
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Strategic Importance — High
Program Evaluation is central to achieving the
future vision of the EPA hazardous waste
program, as expressed in the evolving OSW
Strategic Plan. Program Evaluation is highly
interdependent with Program Implementation,
which generates information used for
measurement and evaluation. This Program Area
includes the development of measurements that
can be used to assess the overall progress of the
RCRA program in protecting human health and
the environment. There are two types of
measurement and evaluation activities: 1) the
traditional approach of measuring the
performance of state, tribal, and regions based on
program activities and 2) the increasingly
important approach of developing more direct and
meaningful indicators that measure actual
environmental improvements. The activities hi
Program Evaluation work toward ensuring that
RCRA is protective of human health and the
environment and results can be measured and
demonstrated. The activities also address
disseminating hazardous waste program
information to the public and regulated
community and meeting the requirements of GPRA. As such, the activities in Program
Evaluation will create information used in Program Management and Program Development.
Program Evaluation also incorporates a number of areas raised in executive interviews on
program direction. They emphasize moving away from direct implementation and command
and control programs to more flexible approaches. As information managment requirements
are specified from GPRA and NEPPS, these requirements will be incorporated into this
Program Area. The focus is moving toward end results and reinventing programs to enable
states and the regulated community to implement environmental protection and show
compliance more efficiently. The information generated hi this Program Area allows EPA to
shape the scope and depth of its evaluation role and its relationship with stakeholders.
Strategic Importance of Program Evaluation
• Executive View: EPA is changing from
command and control regulatory activities
to providing more flexibility in achieving
environmental protection, including
expanded use of voluntary actions and
initiatives; EPA continues reinvention and
streamlining activities for the existing
program and makes it simpler and less
burdensome for facilities to show
compliance with environmental regulations
and other performance standards; and
RCRA will place less emphasis on program
activities and more emphasis on
environmental results to measure program
success.
• Goals: RCRA is protective of human health
and the environment and focuses more on
results than process; and hazardous waste
program's effectiveness in protecting
human health and the environment can be
measured and demonstrated.
• Strategies: Program improvements,
program measurement and evaluation, and
information dissemination.
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Current Systems Support — Medium to Low
Current Systems Support for Program Evaluation
Need for Improvement: The current systems
maintain information designed to track the
regulatory process and regulated waste activity, not
the environmental results of those activities.
Reliability of information from sources =
Medium/Low Accessibility of information from
sources = Low
The key information gap for
Program Evaluation is a lack of
supporting information to evaluate
environmental results. Current
information is designed to track the
regulatory process and regulated
waste activity, not the environmental
or human health results of those
activities. While EPA appears to
have a continued need for information
about regulatory process and
regulated waste activity, the focus must be on directly collecting information related to
environmental results plus linking information about program activity to the information that
quantifies the environmental and human health outcomes of those activities. In addition, the
field of program evaluation is expanding. Measurements under GPRA, environmental
indicators and goals, are still being developed. These measures may require new types of
information regarding environmental status that we currently do not collect. There will be a
large gap between information available today and that which will be needed to meet these
growing needs. A future challenge in this Program Area will be to identify the intended
environmental outcomes for the many hazardous waste program activities.
(Ranking: Tied for 2)
Activities include the following: provide access to program information, assess program
technology needs, develop mechanisms for information collection, integrate information,
provide mechanisms for disseminating information, implement data security mechanisms,
and maintain catalog of information definitions.
Groupings of information needs include the following: information technologies.
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Strategic Importance — High
Information sharing is highly interdependent
with all other Program Areas in terms of
information management. The activities
include the integration and dissemination of
data and information. The information
management activities provide the mechanics
for receiving and disseminating information
among all other Program Areas.
Information Sharing focuses on the activities
of transferring information among program
stakeholders. Managers noted that
information must get into the hands of
stakeholders to promote more effective
participation in environmental decision
making, ensure consistent implementation of
the program, and facilitate multi-media
analyses. As noted during facilitated
sessions, a number of the program staff
concerns were related to the burdensome
mechanics of inputting and accessing
information in the EPA hazardous waste
program. Addressing these difficulties
would increase the usefulness of the
information and ultimately the quality of the
data. Hence, by improving activities in
Information Sharing, one addresses the goal
of making RCRA information more accurate, accessible, easy to use, and useful and satisfies
the strategies associated with information dissemination and gathering.
Strategic Importance of Information Sharing
• Executive View: Information must be made
available and explained to the public to
promote local stakeholder participation;
hazardous waste information must be
integrated with EPA information systems as
well as other outside information systems to
support multi-media activities; hazardous
waste program information must be made
available to analysts, less resource
intensive to maintain, and of higher quality
to support quality scientific and technical
analyses; to ensure consistent
implementation of the program, EPA must
provide greater access to certain types of
program information;jto reduce
unnecessary burden, EPA must strive to
identify and maintain fundamental core
information to support the program while
minimizing the burden of collecting and
maintaining RCRA information.
• Goals: EPA provides RCRA information
that is accurate, accessible, easy to use,
and useful.
• Strategies: Information dissemination and
information gathering.
Current Systems Support — Medium to Low
The major gaps in the current systems that support Information Sharing are 1) the relative
inaccessibility of current hazardous waste information and 2) a lack of support for integrating
the volumes of hazardous waste information that currently exist in both formal databases and
collections of text documents ranging from regulations, policy, and guidance to special studies
and reports. Interviews revealed that most EPA analytical projects will continue to require the
ad hoc integration of hazardous waste, scientific, demographic, and multi-media information
obtained from diverse sources.
6-10
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Access to hazardous waste information can be
significantly improved using technologies that provide
subject-based access to information in varied formats.
Information integration is also improved by subject-
based access technologies, but these must be
supplemented with documentation that describes how
information for a given subject can be integrated. The
ongoing challenges for this Program Area will be to
develop technologies supporting easy access to current
and future hazardous waste information and to
simplify integration of this information with scientific,
demographic, and multi-media information.
Current Systems Support for Information Sharing
Need for Improvement: The ongoing challenges for
this Program Area -will be to develop technologies
supporting easy access to current and future
hazardous waste information and to simplify its
integration with scientific, demographic, and multi-
media information sources.
Reliability of information from sources = Medium
Accessibility of information from sources = Low
(Ranking: 3)
Activities include the following: develop regulations and develop non-regulatory
approaches.
Groupings of information needs include the following: regulation and policy and guidance
Strategic Importance — Medium
Program Development incorporates a number of
elements key to the hazardous waste program. This
Program Area includes the development of
alternatives to regulatory and standards development,
which were strategic goals noted for the EPA
hazardous waste program. Through development of
voluntary programs and multi-media approaches, this
Program Area incorporates the goals of focusing
RCRA on results versus process, integrating a multi-
media environmental approach into the program, and
promoting source reduction and waste minimization.
This Program Area includes the activities necessary
to make the program easier to implement, such as
clarifying regulations to make them easier to
understand and to improve compliance. Program
Development addresses one of the major goals of the
program - making RCRA easier to understand.
Strategic Importance of Program Development
• Executive View: EPA's program
activities will need to be integrated with
EPA's multi-media approaches to
environmental protection; and the EPA
hazardous waste program will be
incorporating more risk-based decision
making into all program development,
implementation, and evaluation
activities.
• Goals: RCRA is protective of human
health and the environment and focuses
more on results than process; the RCRA
program integrates a multi-media
environmental protection approach;
RCRA is easy to understand; and RCRA
promotes source reduction and waste
minimization.
• Strategies: Program improvements.
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The voluntary program development and multi-media activities also support the program
improvement strategies emphasized by staff during the facilitated sessions. They also are
consistent with the management viewpoint of the EPA hazardous waste program moving
toward a multi-media and location approach to environmental protection, as well as
incorporating risk-based decision making into program development activities.
In terms of information management, one key to this Program Area is having adequate and
reliable data available upon which to base the technical and policy decisions inherent in every
rulemaking and guidance development effort. Management and staff involved in rulemaking
and guidance efforts are frequently confronted with inadequate data about the regulated
community, and hi some cases, the resulting regulations or guidance may not be as clear and
appropriately targeted as possible. To meet the vision of an EPA hazardous waste program,
adequate information must be available to accurately describe the characteristics of the
regulated community and risks to the environment and human health. Such information is
necessary whether developing regulatory or nonregulatory programs.
Current Systems Support - Medium
The major gap in current systems support
for Program Development is that existing
hazardous waste information does not
effectively support multi-media and industry
sector analysis.
The major improvements hi information
support for Program Development will be
achieved through increased accessibility to
current hazardous waste information,
enhanced support for multi-media and
industry sector analysis, and enhanced
methods for integrating this information with
information from other sources. These
improvements will be largely addressed by the information access and integration projects
pursued under the Information Sharing, Program Evaluation, and Program Implementation.
To effectively evaluate and manage changes in the program (e.g., regulations, policy,
guidance), this Program Area must consider integrated methods for maintaining a program
wide view of the hazardous waste information requirements mandated by statutes, regulations,
policy, and guidance.
Current Systems Support for Program Development
Need for Improvement: The major improvements in
information support for this Program Area will be
achieved through increased accessibility to current
hazardous -waste information, enhanced support for
multi-media and industry sector analysis, and enhanced
methods for integrating this information with
information from other sources.
Reliability of information from sources =
High/Medium Accessibility of information from sources
— Medium/Low
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(Ranking: 4)
Activities include the following: identify and prioritize national program areas; define
EPA partnerships and stakeholder roles; conduct strategic planning; assess strategic
information needs of the program; prioritize and track program resources; establish
program direction; plan implementation programs and resources; authorize states/tribal
programs; negotiate and track state grants; and establish performance partnerships.
Groupings of information needs include the following: program, program plan, program
cost, and program resource.
Strategic Importance - Medium
The strategic importance of Program
Management rests primarily on two areas.
First, protecting human health and the
environment is a key goal of this Program
Area. Second, two of the
activities—establishing stakeholder
partnerships and authorizing stakeholder
partnerships—highlight the concept of
EPA-stakeholder partnerships. The
partnership concept focuses on EPA and its
stakeholders working together to take on the
challenges of implementing the hazardous
waste program. The activities hi this Program
Area address the goal of maintaining effective
and efficient partnerships with stakeholders.
The activities also reflect the strategies of implementing program improvements by improving
stakeholder partnerships and making resources available through resource and fund
management.
Strategic Importance of Program Management
• Executive View: Integration of program
management and information
management.
• Goal: RCRA is protective of human
health and the environment and focuses
more on results than process; EPA
maintains effective and efficient
partnerships with stakeholders.
• Strategies: Program improvements and
resource availability.
Current Systems Support - Medium
Current systems support Program
Management by providing baseline
information about program implementation
activities, regulatory processes, and
regulated waste activities. Program
Management relies upon the Program
Current Systems Support for Program Management
Need for Improvement: The major gaps in current
systems support for Program Management are a
lack of information supporting multi-media and
industry sector-based assessment of environmental
results.
Reliability of information from sources = Medium
Accessibility of information from sources =Medium
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Evaluation activities to determine what has been accomplished and to define what needs to be
accomplished. The major gap in current systems support for Program Management is the lack
of information supporting multi-media and industry sector-based assessment of environmental
results. A major challenge for this Program Area will be to identify the intended
environmental outcomes for the many hazardous waste program activities and to develop
methods for allocating program resources to achieve the desired environmental results.
(Ranking: 5)
Activities include the following: analyze industrial waste information; identify high-risk
wastes; conduct waste management risk assessment; conduct waste characterization,
waste management, and economic studies; conduct impact assessments; and develop
methods and technologies.
Groupings of information needs include the following: method and technology, research,
risk measurement, and waste.
Strategic Importance - Low
Studies and Research is interdependent with
Program Development because it generates
information needed to support many of the
program development activities. The goal of
basing RCRA on sound science originates hi
this Program Area. The activities hi this
Program Area depend on studies and
research conducted to identify wastes and
waste management practices of concern and
the risks to human health and the
environment that result from those waste
management practices. Within this Program
Area, it is essential to ensure availability of .
the research, science, technical, and modeling information needed to conduct studies that
provide meaningful scientific and technical information (including risk) for the EPA hazardous
waste program.
The goal of sound science within the hazardous waste program is linked to risk-based decision
making. This Program Area contains categories of strategies emphasizing risk-based decision
making when developing programs and targeting decisions. The management view of the
program includes the concept of incorporating risk-based decision making into all program
Strategic Importance of Studies and Research
• Executive View: The EPA hazardous waste
program mil be incorporating more risk-
based decision-making into all program
development, implementation, and
evaluation activities.
• Goal: RCRA Program is based on sound
science.
• Strategies: Risk-based Decision Making
and Program Improvement.
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development and implementation activities, as well as management and budget decisions.
Studies and Research generates the information needed to develop risk-based programs and
make risk-based targeting decisions in other Program Areas. Activities in this Program Area
specifically deal with studies and research aimed at identifying high risk wastes and waste
management activities. Information generated as a result of this activity would support
activities within Program Development, Program Management, Program Evaluation, and
Program Implementation.
Current Systems Support - Medium to Low
Hazardous waste studies and research
support Program Development and
Program Management by identifying the
environmental risks associated with
specific solid wastes and the methods
used to manage these risks. This activity
requires staff to combine information
from a wide range of scientific, technical,
and programmatic sources. The primary
weaknesses in current systems support for
this Program Area are that many current
systems are difficult to access and that it
is difficult to combine information
obtained from current internal and external
Current System Support for Studies and Research
Need for Improvement: The primary weaknesses in
current systems support for this Program Area are
that current systems are difficult to access and that it
is difficult to combine information obtained from
current internal and external information sources.
Reliability of information from sources = Medium
Accessibility of information from sources =Low
information sources.
Interviews of program staff responsible for Studies and Research indicated a high degree of
confidence in information obtained from sources that organize information based on
geographic location (GIS). This finding highlights the fact that physical location information
provides one of the most effective tools for combining and organizing diverse information
derived from many sources. Analysis for this Program Area must include consideration for
how the results of individual studies and research can be integrated with information
maintained in future hazardous waste program support systems. The requirement to support
analysis based on physical location and industry sector must be addressed for each PAA.
Successful implementation of this requkement will greatly improve EPA's ability to combine
information from multiple sources.
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(Ranking: 6)
Activities include the following: support other government activities on wastes; support
legal defense of regulations, policy, and guidance; coordinate implementation approach;
provide guidance, training, and technical assistance; solicit feedback; establish
internal/external program communication; conduct stakeholder outreach activities; and
respond to information requests.
Groupings of information needs include the following: stakeholder feedback, information
request, training, and technical assistance.
Strategic Importance - Low
Strategic Importance of Program Implementation
Support
• Executive View: To ensure consistent
implementation of the program, EPA must
provide greater access to program
information.
• Goal: EPA maintains effective and efficient
partnerships with stakeholders.
• Strategies: Information dissemination and
information gathering.
This Program Area is highly interdependent
with Program Development and Program
Implementation. As the Agency moves out
of the direct implementation role, the
activities of this Program Area—training
support, technical assistance, communication
and outreach, handling of information
requests, and managing stakeholder
feedback—use the products of the Program
Development and communicate them to the
implementors of the program (states and the
regulated community). The activities in this
Program Area support the goal of maintaining effective and efficient partnerships with
stakeholders.
The activities in this Program Area also address the strategies of improving information
dissemination and information gathering with stakeholders. Making information about the
RCRA program more available to the stakeholders will assist in understanding and
implementing the program. Activities hi Program Implementation Support also include
collecting stakeholder feedback and collecting uiformation requests to assist stakeholders hi
understanding the program and improving implementation and compliance. These strategies
also reinforce the executive view that EPA must make program activity information (e.g.,
regulatory interpretations, proposed rulemakings) more available to ensure consistent
implementation of the EPA hazardous waste program.
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Current Systems Support for Program Implementation
Support
Need for Improvement: The challenges for this
Program Area will be determining what information
about stakeholder lists must be maintained,
developing a process for maintaining those lists, and
identifying methods for making those lists accessible
to EPA staff based on stakeholder environmental
interests.
Reliability of information from sources = Medium
Accessibility of information from sources =Medium
Current Systems Support - Medium
The key information requirements for this
Program Area are information that
identifies the roles and responsibilities of
stakeholders and information that
identifies the training and technical
assistance requirements for those
stakeholders. With the exception of
regulated stakeholders, these
requirements are not currently supported
by automated information systems.
Rather, program staff indicated that they
rely on stakeholder lists maintained
individually or within their organizational niche. These lists are usually developed and
maintained for specific or ongoing projects. While most staff thought their stakeholder lists
were accessible and of high quality, there are many weaknesses inherent in isolated list
management.
The primary weakness in current stakeholder list management is inconsistency. Because the
stakeholder lists are individually maintained, they are not easily accessible and cannot be
managed to reflect contact changes in stakeholder organizations. Staff from different EPA
organizations end up communicating with different stakeholder representatives regarding the
same or related subjects. Perhaps most important, there is no centralized or uniform process
allowing stakeholders to identify or update information about who will represent them for a
given subject, and EPA has no way of distributing such representational changes when they
occur. The challenges for this Program Area will be determining what stakeholder lists must
be maintained, developing a process for maintaining those lists, and identifying methods for
making those lists accessible to EPA staff based on stakeholder environmental interests.
6.3.3 Evaluation of Program Areas and Identification of Short-Term Projects in Light of
Internal and External Factors Influencing the RCRA Program
In addition to evaluating the Program Areas on strategic importance and current systems
support, EPA also examined the various external and internal Agency influences that could
impact RCRA information management. These influences, listed and described in Exhibit 6-2,
include the following:
• Key Identifier Initiative.
• One-stop Reporting Initiative.
• Public Access Committee.
• Burden Reduction Initiative.
Project XL and CSI Proposals.
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GPRA.
• Manifest IG Audit and ICR Renewal/OMB Recommendations.
• BRS IG Audit and ICR Renewal/OMB Recommendations.
• Commitment to Investigate Notification Reinvention.
• TRI Expansion.
• GAO Concerns about Waste Minimization (Source Reduction and Recycling)
Information.
• Information Management Initiative/Reform Demand - ISO 14000 Environmental
Management Standards.
In addition to these program drivers, EPA also must consider 1) Office of Administration and
Resource Management's (OARM's) announced intention to move existing and future
information systems to a new software platform (i.e., Oracle) and 2) the RCRA stakeholders'
need to take the results of the RCRIS Lessons Learned Project into account when moving
forward with any information management project (see Appendix I for the RCRIS Lessons
Learned Briefing)1.
Program Areas
EPA evaluated the Program Areas against these internal and external factors and found that the
rankings identified in Section 6.3.1 do not change. Specifically, EPA determined that
Program Implementation will continue to be a high priority because it contains the activities
and information that center around the Key Identifier Initiative, the Burden Reduction
Initiative, the Manifest IG Audit and ICR renewal, the BRS IG Audit and ICR renewal,
Notification Reinvention, TRI expansion, and the GAO concerns about source reduction and
recycling information. Program Evaluation and Information Sharing continue to be the second
most important Program Areas. Program Evaluation will need to address key Agency
program influences, including GPRA as well as support the current Project XL and CSI
proposals. Information Sharing, on the other hand, is designed to work with and address
recommendations from the Public Access Committee. It also targets one of the key
recommendations of the RCRIS Lessons Learned Project: to make information more
accessible. Thus, the priority determinations are viewed as consistent with the general themes
and directions of EPA.
'Initiated in December 1995, the RCRIS Lessons Learned Project was conducted in response to
the GAO report published on RCRIS. The purpose of the project was to examine the systems
development and implementation history of RCRIS, understand its accomplishments as well as its
shortcomings, and identify what should and should not be done in future system development efforts for
the RCRA program.
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Information Management
Initiative/Reform Demand
Facility Identification (Key Identifier)
' Initiative
One-stop Reporting Initiative
Public Access Committee (PAC)
Burden Reduction Initiative
Project XL and CSI Proposals
GPRA
Concept for Inclusion into the Program
Area Analysis (PAA) Methodology
Data system linkage; similar core facility
information
Place-based, multi-media, consolidated
reporting
Accessible and understandable information
for public use
Burden reduction; calculation of burden
with all PAA options and
recommendations
Ideas for piloting changes in information
reporting by regulated community
Methodology for measuring environmental
and health results.
Activities or Concerns that
Need to Considered by PAA(s)
FR Notice about concept with
option in September 1996
Study initiated in September
1996 on data overlaps
IRM ESC plans and meeting
notes with stakeholders
documenting issues; CEIS
Report developed in December
1995 but never released due to
OMB concerns about baseline
calculations
Several project XLs are piloting
streamlining concepts; metal
finishing CSI will have
information streamlining
recommendations (RIITE
Project)
Need to develop measurements
Program Area (PA) Affected
Program Implementation
Program Implementation
All PAs
All PAs
All PAs
All PAs
Exhibit 6-2. Overview of External and Internal Influences Affecting Information Management
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Information Management
Initiative/Reform Demand
Manifest IG Audit and ICR
Renewal/OMB Recommendations
BRS IG Audit and ICR
Renewal/OMB Recommendations
Commitment to Investigate
Notification Reinvention
TRI Expansion
GAO Concerns about Waste
Minimization (Source Reduction and
Recycling) Information
Information Management
Initiative/Reform - ISO 14000
environmental management standards
Concept for Inclusion into the Program
Area Analysis (PAA) Methodology
Information appropriate to need/less cost
and more effective/
burden reduction
Information appropriate to need/less cost
and more effective/
burden reduction
Information appropriate to need/less cost
and more effective/
burden reduction
Place-based, multi-media reporting
Importance of source reduction and
recycling measurement
New industry approaches for implementing
environmental management systems (i.e.,
environmental auditing and environmental
performance evaluation) and pollution
prevention activities
Activities or Concerns that
Need to Considered by PAA(s)
Final IG report documenting
concerns/ recommendations;
OMB concerns documented in
Reg/Neg
Report on reinventing
regulation, including
commitment to consider
reduction in notification burden
Proposal published in June 1996
GAO concerns documented in
report; also, four state pilot
studies and WMB measurement
project
EPA standards network
(OPPTS) serves as focal point
for Agency-wide input to
standards development; need to
stay current with pilot projects
and standards requirements
Program Area (PA) Affected
Program Implementation
Program Implementation
Program Implementation
Program Implementation
Program Implementation
AUPAAs
Exhibit 6-2. Overview of External and Internal Influences Affecting Information Management (continued)
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Short -Term Projects
A number of short-term information-related projects will be or have been initiated in response
to these program influences. Although some short-term projects do not represent RCRA
community-wide efforts, these projects provide certain interim solutions until the longer-term
PAAs are conducted and resulting system improvements are implemented. While these short-
term projects did not originate in direct response to this ISP, they were identified as supporting
the Program Areas in this ISP. EPA analyzed these short-term projects to determine their
scope and impact on the results of this ISP. In addition, EPA analyzed the resource
requirements of the short-term projects to determine the impact of their implementation on the
resources available for other WIN-related activities.
The outcomes of these short-term projects may have a direct impact on the follow up PAAs
soon to be conducted for the top three Program Areas. Note that the follow up PAAs are
essentially detailed system requirements analyses and will have a longer time for completion
than some of the short-term projects. (Chapter 7 discusses in more detail the process for
conducting the PAAs.) Moreover, all of the short-term projects support one of EPA's top
three Program Areas. Hence, the outcomes of the short-term projects will have an impact on
the results of the PAAs and vice versa.
Exhibit 6-3 lists the short-term, information-related projects EPA evaluated to determine the
potential impacts on and relation to the Program Areas, particularly the top three. Based on
the Agency program influences, the following short-term projects are recommended as
priorities for OSW for FY 1997 and FY 1998:
1. BRS Changes - supports Program Implementation.
2. RCRA Policy Index System - supports Information Sharing.
3. Access to RCRIS/BRS National Data - supports Information Sharing.
4. RCRIS Streamlining - supports Information Sharing.
5. RCRA Docket Indexing Systems - supports Information Sharing.
6. Special Analyses - supports primarily Program Implementation.
The Enforcement Initiatives will be primarily conducted by the Office of Enforcement and
Compliance Assistance. One should note that conducting the above projects has the potential
to impact resources that would otherwise be devoted to PAAs. The probability and magnitude
of such impacts is not currently known.
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BRS Changes - Implementing the 1997 biennial report changes (revise forms;
hotline support for calls; develop, implement, and document software to support
changes; and provide training to regions/states).
RCRA Policy Index System - Define, design, develop, implement, and document a
searchable database on the Internet, containing policy and guidance documents.
Access to RCRIS/BRS National Data - Move the RCRIS and BRS to an Oracle
database structure to shadow the existing Focus databases. This does not change
current systems but allows EPA to make the RCRIS and BRS databases available on
a platform that supports integrated query with other EPA national systems.
Special Analysis - Respond to analysis requests on information projects; including
TRI expansion proposal, RIITE, manifest initiatives, IG notificatipn issues, GAO
waste minimization issues, key ID, and XL reviews.
Enforcement initiatives:
Sector-Based Tracking: The sector divisions in the Office of Compliance
will identify patterns of noncompliance within specific economic sectors
(industrial groups) and devise appropriate compliance assurance and
enforcement strategies to correct violations.
Enforcement Sensitive Definition: OECA has been redefining what is
releasable undef FOIA. The biggest implications are on RCRIS — more
data will be releasable than was previously allowed, more than from any
other data base.
Compliance Assistance: The Sector Divisions in the Office of Compliance
will develop programs that help to organize and better explain different
environmental requirements that affect the same industry. As a first, the
Office of Compliance is developing "compliance assistance centers" to
help those small business sectors with significant regulatory requirements.
RCRIS Streamlining - Support OSW's effort to minimize state and regional
requirements to submit certain information to the national oversight databases.
RCRA Docket Indexing System - Support OARM in conducting a feasibility study
that determines the type and scope of a database index that would serve the needs of
the docket and its users.
Exhibit 6-3. List of Short-Term Projects to Support the EPA Hazardous Waste
Program
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7.0 TRANSITION PLAN
This chapter describes a transition plan to implement the findings of this ISP and to address
EPA's information management requirements. Based on recommendations from Chapter 6,
the transition plan recommends priorities for FY 1997 and FY 1998, including resources
needed, schedules, and outputs/outcomes for the Program Area Analyses and priority short-
term projects. This chapter also identifies key principles that EPA believes each PAA and
short-term project must address and incorporate into any subsequent planning and design
activities. In addition, this chapter describes a framework and issues for successful EPA/state
coordination.
This chapter addresses the following areas:
• Key questions answered by this chapter.
• Key findings identified through development of the transition plan.
• Discussion of the relevant topics, including the implementation process of the transition
plan in terms of key programmatic principles that must be addressed by each PAA and
short-term project, a recommended framework for close EPA/state coordination, the
methodology for conducting the PAAs, and proposed projects in terms of both PAAs
and priority short-term projects.
• A discussion of other issues that should be addressed by EPA and/or states.
7.1 KEY QUESTIONS
What is EPA's proposed PAA transition plan, including projects, resources, schedules, and
outputs/outcomes?
What are the key principles to consider hi conducting the PAAs and short-term projects?
What are the issues concerning the successful coordination of EPA (both headquarters and
regions) and state PAAs and what is the appropriate framework for resolving these issues?
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7.2 KEY FINDINGS
• EPA will not be able to accomplish all of the many short- and long-term information
management needs hi the next 2 fiscal years. Consequently, priorities must be
established and sufficient resources must be committed for both the short- and long-
term phases of implementing this ISP and pursuing the overall WIN Initiative.
However, all of the short- and long-term initiatives will be pursued, either on a high-
priority track or as part of PAA efforts.
• Program Implementation, Program Evaluation and Information Sharing — the three
EPA priority Program Areas selected for detailed PAAs (the next step in the WIN
project) — can be initiated and completed hi the next 2 to 3 years within realistic
resource scenarios (provided an appropriate issue resolution framework is also
established).
• All PAAs and short-term projects must address certain key principles to ensure
consistent and coordinated movement toward unproved RCRA information systems.
• The nine priority short-term projects identified in the transition plan probably can be
continued within realistic resource scenarios. However, if additional short-term
projects are imposed outside the boundaries of the PAAs, such projects are likely to
have a direct negative impact on the number and pace of the PAAs.
• Immediate initiation of certain short-term projects could lose the benefits associated
with the comprehensive approach of PAA project analysis and design. When short-term
projects are initiated hi this manner, the risks can, however, be minimized if they
follow all the key principles and are coordinated with PAAs to the maximum extent
possible.
• Successful PAAs and short-term projects will require all EPA organizations (i.e.,
OSW, OECA, and regions) to make the necessary long-term commitment of personnel
- both management and staff - and sufficient extramural resources.
• To leverage resources and ensure successful integration of interrelated program areas,
EPA, states and others (including tribes as feasible) must establish effective
partnerships and adopt a shared vision for implementation of PAAs. An EPA/state
steering committee should serve as the principal mechanism for ensuring these
outcomes.
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• Resource requirements for the top three priority PAAs are presented as preliminary
estimates. The degree of coordination with states will have a significant impact on the
resources actually required. In addition, existing short-term projects and any new
short-terms projects will affect resource requirements.
• EPA must continue to support existing information systems (e.g., RCRIS) during the
transition, while maintaining an appropriate level of awareness of information
technology trends when contemplating interim improvements to RCRIS.
7.3 DISCUSSION
7.3.1 Implementation Process
This section describes the implementation process for EPA's PAAs and short-term projects in
terms of six key principles that are critical for success and a framework for close state/EPA
coordination.
Key Principles
In the many interviews, focus groups, and discussions conducted while preparing this ISP,
stakeholders identified a number of issues that were regarded with sufficient significance to
warrant special consideration in the PAAs and short-term projects. EPA refined these issues
into six key principles, which are identified and briefly described in the paragraphs below.
Core Information Needs/Burden Reduction. Core information needs must be identified, and
reporting and record-keeping burdens should be reduced wherever possible in response to
reinvention efforts for environmental regulation. A major EPA commitment is to streamline
unnecessary reporting requirements and reduce the record keeping and reporting burden on
the regulated community. However, as noted hi Chapters 2 and 3, the information needs of
program staff do not appear to be significantly decreasing. In addition, new information needs
will continue to be identified in the area of program evaluation. To achieve the desired
reduction in the record keeping and reporting burden, priority and core information needs
should be identified. Tough choices and determinations regarding the relative importance of
supporting information may have to be made across various program activities. To facilitate
this, the PAAs should be shared and understood by both EPA and the states. This will better
foster elucidation of the core information that the RCRA program will require, at a minimum,
to function.
Consistent Definitions. Program and information system definitions must be more consistent to
promote integration and utility of data. Under RCRA's statutory scheme, state program
requirements and associated definitions do not have to be identical to the EPA's. However,
these inconsistencies in program definitions have continued to plague national data systems,
including RCRIS and BRS. The inconsistencies have resulted in increased confusion and
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difficulties in entering and checking data, as well as in programmatic use of the data. Program
differences in definitions should be resolved in a manner that promotes integration, while
allowing the needs or characteristics of individual programs (both federal and state) to be
maintained where feasible.
During the PAAs, it will be crucial to identify elements with definitional variances, and where
possible, to develop common definitions and consistent interpretations prior to developing
information systems. The development of this common understanding of terms will require
coordination among existing regulatory definitions and consultations with program experts
across all affected programs at both the federal, state, and tribal levels.
Co-regulation/Partnership Framework. All work on PAAs must recognize and accommodate
the various roles of EPA, states, and tribes in reaching solutions to information collection,
integration, and dissemination issues, especially to the degree that EPA continues to perform
some level of program implementation. The hazardous waste program is implemented through
a partnership between EPA and state (and in some cases tribal) programs. States, in
particular, are responsible for implementing the portions of the hazardous waste program for
which they are authorized. At an individual facility, EPA and a state or tribe may have full or
partial jurisdiction for implementing separate components of the hazardous waste program
(e.g., permitting and corrective action). Consequently, both EPA and a state or tribe may be
creating/managing similar information for a single facility. This situation raises the issue of
how and where certain information is best managed, at the state/tribal or national level.
The PAAs should resolve the issue of co-regulation (EPA/state/tribal roles, responsibilities,
information sharing) prior to any system design efforts. EPA and states must investigate the
varying demands for information in the Program Areas from all implementors of the hazardous
waste program. The analysis should identify a number of items, including the specific needs
of each organization. Where needs conflict, the analysis should indicate how and where
information will be managed to accommodate the varying needs, but to avoid the pitfalls of
non-integrated information systems.
Information Accessibility. Information must be readily available, easy to maintain, and of high
quality for use by EPA, states, tribes, and the public. EPA's role is evolving from direct
implementor to working partner with RCRA stakeholders (i.e., states, tribes, industry, and the
public). Through the ISP process, it is clear that all stakeholders require increased accessibility
to information. For example, information systems must provide local communities with
essential data in a user-friendly format to support community-based environmental protection
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projects. The PAAs therefore, should address the issue of accessibility and identify
opportunities (e.g., structural and technological) for improving the accessibility of information
at all levels.
Multi-media Focus. Hazardous waste information must be integrated with other Agency and
non-Agency information systems to support multi-media and other Agency initiatives. There is
a clear shift in EPA programs toward multi-media emphasis and the concomitant need to
integrate several databases and information systems to analyze cross-media impacts and
implications. For example, the Agency is developing multi-media performance measures to
demonstrate success rather than more traditional program-specific activity measures. In
addition, community-based environmental protection initiatives require multi-media
information. The PAAs should therefore identify information of importance to multi-media
projects as well as develop options for meeting these needs.
Technology Assessment. As PAAs and short-term projects are initiated, EPA must evaluate
technologies carefully so that they meet user requirements and can be realistically implemented
by the program stakeholders. EPA noted that it will be important for the PAAs and short-term
projects to apply the guiding principles on technology, as discussed in Chapter 5. This theme
was highlighted during the RCRIS Lessons Learned project, which stated that future system
development efforts must carefully examine the technologies and select ones that are stable and
adequately address the information requirements of the users. As PAAs and short-term
projects are conducted, EPA should begin examining technologies, particularly as project
participants get closer to identifying the exact data and activities that need to be tracked. It
will be important to evaluate the technologies based on a set of assessment criteria that reflect
the user requirements for collecting, integrating, and disseminating information. A thorough
technology assessment will help minimize the selection of a technology solution or set of
solutions that are not appropriate to address the information management requirements of the
PAAs.
State/EPA Partnership
The states and EPA agree that the INFORMED and WIN initiatives cannot achieve their
objectives unless both partners (and tribes as feasible) work together to resolve issues, identify
needs, and recommend solutions. There are some issues (e.g., what are the core data elements
of a certain Program Area) that can be resolved during the PAAs. Other issues — core
information needs/burden reduction, consistent definitions, and co-regulation/partnership
framework — cut across some or all of the Program Areas. The process likely will operate
more efficiently if these issues are resolved prior to, or at least in an appropriate timeframe
with respect to, initiation of any PAA.
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Both INFORMED and WIN are long-term solutions to the RCRA program's data needs. All
partners must seek and make long-term commitments, both hi tune and resources, to make
these efforts succeed. EPA and the states need to establish principles for how tasks will be
accomplished, when tasks will be accomplished, and how the partners will work together early
in the transition phase from ISP development to the PAAs. To the extent feasible, consistency
across PAAs will move the process faster and help avoid revisiting issues. All partners need
to work together to fully scope out the joint Program Areas and to develop project
management plans that clearly identify major milestones, deadlines, and roles.
The coordination structure established for development of the ISPs — executive steering
committee, ISP steering committee, and various working groups — may not have resulted hi
maximum clarity for defining roles and responsibilities or worked as efficiently as possible.
Additional complexities during the PAAs (e.g., cross-PAA issues) support a more streamlined
and efficient organizational approach. One option is to have State/EPA Work Teams, a PAA
Coordinating Committee, and an Executive Steering Committee with the following
responsibilities:
• State/EPA Work Teams: These Teams would consist of the analysts and information
specialists conducting the PAAs and would be responsible for routine communication
and coordination. While the Teams would make recommendations on all aspects of the
PAAs, decision-making authority would be limited to how the work is accomplished.
• PAA Coordinating Committee: The Coordinating Committee would include one staff
member from each ongoing PAA (or one state staff member and one EPA staff member
from each ongoing PAA), two EPA headquarters managers, two EPA regional
managers, and two state managers. The Coordinating Committee would be responsible
for resolving any issues raised by the Work Teams and overseeing resource allocations.
The Committee would have first-level decision-making authority and would bring any
issue on which they could not reach consensus to the Executive Steering Committee.
• Executive Steering Committee: The Executive Steering Committee would include two
upper management-level representatives each from EPA headquarters, EPA regions,
and the states. The Executive Steering Committee would be responsible for resolving
any issues raised to it by the PAA Coordinating Committee and would have overall
decision-making authority.
7.3.2 PAA Methodology
The following discussion provides an overview of the PAA methodology. The intent is not to
present a detailed description of the process, but to provide a general understanding of the
elements of a PAA with respect to the resource discussions given in Section 7.3.3.
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Key Steps
PAA involves five key steps: scoping a PAA, activity analysis, data analysis, interaction
analysis, and confirmation. Each of these steps, including its purpose and key outputs, is
briefly described below.
Scoping a PAA. The first step of a PAA is to identify key stakeholders and decision makers,
determine the scope of the Program Area, identify anticipated outcomes and products from the
analysis, select techniques for involving participants (e.g., interviews, facilitated sessions),
identify key decisions, if any, that have been made (e.g., definitions), list key principles that
need to be addressed, select team members, and determine time commitments. The project
leader should develop the project management plan during this step and provide team members
with background documents (e.g., the ISP) to ensure all team members have an indepth
knowledge of project scope, background, and objectives. In scoping the Program Area, the
project leader would also identify where potential activities or information needs may overlap
with other PAAs and how such overlaps will be resolved during the analyses. The Project
Managment Plan, developed in the initial phase of scoping, will address the overlap issues.
Activity Analysis. During this step, team members work with staff hi the Program Area to
refine the high level activity categories identified in the ISP and determine specific sub-
activities within those categories. For example, the high level activity "permitting" is divided
into a series of sub-activities, such as reviewing the permit application, providing comments to
the permittee, and setting up a public hearing. By identifying a complete and accurate list of
activities and subactivities, the team prepares for the next step of data analysis. Also, as part
of this activity analysis, process improvements are identified that would result in changes in
how the Program Area is implemented and data managed.
Data Analysis. The third step, data analysis, defines the data elements needed to perform the
tasks identified in the second step. During this step, team members also identify clarifying
characteristics of the activities and associated data element needs. For example, the high level
information category of "program operations, plans, and evaluation information -
environmental indicators" is broken down into a series of specific data elements, such as
measurement of toxic levels in the environment. Team members would work with permitting
staff to answer such questions as the following: Does EPA or the states issue a handler one or
more permits? Do EPA and the states need to know only about RCRA permits, or do
permitting staff need to know about other media permits? Identifying a complete and accurate
list of data element needs will provide the basis for identifying core data needs. This step will
result in a complete list of data elements, identification of core data elements, and
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determination of the relationships among data elements. As part of this step, the team
members also work with program staff to identify the data essential to supporting the activities
of a Program Area.
Interaction Analysis. The fourth step in a PAA uses the results of the data analysis step to
detennine how the Program Area activities and data element needs interrelate. Team members
would answer a number of key questions, such as the following. Which enforcement activities
create and use specific data elements? Which events trigger an inspection? What data does an
inspector need to conduct an inspection? The interaction analysis step has several functions.
First, it provides .an additional verification point to ensure all activities and all data element
needs have been identified. Second, it determines which activities and which data elements
interrelate so that the impact of any changes in the activities or data elements are understood.
Third, it identifies activities, data elements, or decisions within one Program Area that may
affect another Program Area. Finally, this step also includes a refinement of the Current
Systems Assessment to detennine how data elements are managed and how well the data
management systems are meeting user expectations.
PAA Confirmation. In this final step, the results of the preceding analyses are presented to
management and key decision makers. At this point, managers and key decision makers are
asked to confirm that the list of activities and data elements needs are complete and accurate
and to determine whether these data element needs are truly the core information needs for the
Program Area.
Final Output. The PAA drives the findings of the ISP down to the data element level and
results in the systems specifications for the next phase (design of systems). The systems
specifications include a list of core data elements, definitions of the core data elements, and
identification of accessibility, reliability, and frequency needs for the data elements.
7.3.3 Proposed Projects
This section presents the transition plan for the three priority PAA projects selected by EPA
and the short-term projects that have or will be initiated in the near future. EPA considered
other options for the transition plan. The Agency could, for example, perform
additional/fewer PAAs or additional/fewer short-term projects. The transition plan, presented
in Exhibit 7-1 and Exhibit 7-2, reflects the Agency's attempt to strike the optimum balance
between resource and time constraints versus the necessity for meaningful progress on critical
short-term and long-term improvements to EPA's information management systems. An
expansion of the list of PAAs and short-term projects would require additional resources and
additional commitments from regions, states, and other participants. Unanticipated and severe
budget constraints could also impact progress on priority PAAs or short-term projects.
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Proposed PAA Projects
Using the process described in Chapter 6 of this, report, EPA selected three PAAs for
initiation in FY 97: Program Implementation, Program Evaluation, and Information Sharing.
Exhibit 7-1 provides an overview of the transition plan for these PAA projects and EPA's
participation in priority PAA projects at the state level (i.e., Universe Identification, Waste
Activity Monitoring, and Handler Monitoring and Assistance). The transition plan considers
current and anticipated resource constraints. The next paragraphs discuss the three EPA PAAs
from scope and resource perspectives.
Program Implementation overlaps with three state priority Program Area projects (Universe
Identification, Waste Activity Monitoring, and Handler Monitoring and Assistance) identified
by the states in their INFORMED ISP. In addition, this Program Area covers the analysis and
streamlining of the data elements and the processing of manifests, notifications, and biennial
reports. The analytical model used for the WIN ISP (i.e., IBM) recommends three to four
full-time staff for each PAA, as well as several Program Area staff as needed. Although the
IBM suggests that most PAAs take no longer than 6 to 9 months, the scope and complexity of
this Program Area could require 18 to 24 months for complete analysis and final approval. It
is estimated preliminarily that approximately $600,000 to $1,000,000 over 2 years in EPA
extramural funds will be required, assuming that state efforts will supplement EPA projects.
With the dedication of additional full-time equivalents (FTEs), as well as additional extramural
support, this schedule could be shortened.
Program Evaluation focuses on two main areas, EPA/state partnerships and program and
performance evaluations. Program Evaluation will interact with the National Environmental
Performance Partnerships System (NEPPS) process as well as RCRA GPRA activities, and the
analysis must integrate results from both areas. The evolving nature of Program Evaluation
and the need to interact with two major, ongoing initiatives will add to the time and FTEs
required for planning, coordination, consensus building, and identify ing the measures and
program/performance evaluation methodologies developed through NEPPS and GPRA efforts.
It is assumed that the preliminary recommended $500,000 to $1,000,000 over 2 years in
extramural funds will be supplemented by related ongoing activities (e.g., waste minimization
measurement project). It may be possible to abbreviate the schedule with the dedication of
additional FTEs, as well as additional extramural support. Because measures and evaluation
methodologies are just now being developed, it is expected that the activities within Program
Evaluation will still be expanding beyond the analysis period.
Information Sharing covers assessing technologies, including those that facilitate easy access
and dissemination, and developing and implementing techniques for data collection,
integration, and dissemination. Since Information Sharing supports the other six Program
Areas, this analysis will be ongoing until all PAAs are complete. A specific schedule cannot
be determined until schedules for the other six Program Areas are finalized. While the FTEs
required for Information Sharing are slightly less than those required under the other two
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priority Program Areas, the Information Sharing FTEs must be dedicated for a much longer
period. The preliminary recommended $400,000 to $800,000 over 2 years in extramural
funds will be supplemented by funds provided for the information-related, priority short-term
projects.
Priority Short-Term Projects
Using the process described hi Chapter 6 of this report, EPA identified nine short-term
projects for initiation in FY 96, FY 97, and FY 98. OSW identified the following projects:
Biennial Report (BR) and Biennial Report System (BRS) Changes, RCRA Policy Index
System, RCRIS Streamlining, Access to RCRIS/BRS National Data, RCRA Docket Indexing
System, and Special Analyses. OECA identified the following projects: Enforcement Sensitive
Definitions, Sector-Based Tracking, and Compliance Assistance. Exhibit 7-2 provides an
overview of the transition plan for these projects according to the resources required,
schedule, and major outputs/outcomes. The transition plan considers current and anticipated
resource constraints.
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PROGRAM
AREA
RESOURCES*
SCHEDULE
OUTPUTS/RESULTS
Program
Implementation
4-6 Full Time Equivalents
(FTEs)
Includes Team Leader,
Analyst, Information
Specialist, Coordination
and Logistics, and
participation from several
additional program area
staff
$300,000 - $500,000 in
extramural funds per year
for 2 years
18 to 24 months
(depending on the
process established)
Interim- project
management plan, activity
analysis, data analysis,
interaction analysis; Final
- specifications for next
IBM phase (design)
Program Evaluation
4-6 FTEs
Includes Team Leader,
Analyst, Information
Specialist, Coordination
and Outreach, and
participation from several
additional program area
staff
$250,000 - $500,000 in
extramural funds per year
for 2 years
24 to 30 months
Interim - project
management plan, activity
analysis, data analysis,
interaction analysis; Final
- specifications for next
IBM phase (design)
Information Sharing
2- 4 FTEs
This estimate may
increase based on other
PAAs
$200,000 to $400,000 in
extramural funds per year
for 2 years
Dependent on
schedules for other
PAAs
To be determined
Exhibit 7-1. Preliminary Estimates of Resources, Schedule, and Outputs/Outcomes of
Recommended PAAs
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PROGRAM
AREA
State Projects:
(a) Universe
Identification
(b) Waste Activity
Monitoring and
(c) Handler
Monitoring and
Assistance
RESOURCES*
1 - 3 FTEs for EPA
participation in state
projects
See state INFORMED
ISP for state funds per
year
$TBD in EPA funding for
state projects
SCHEDULE
Preliminary state
estimates:
(a) 26 weeks
(b) 38 weeks
(c) 38 weeks
OUTPUTS/RESULTS
See state INFORMED
ISP for outputs/results
Exhibit 7-1. Preliminary Estimates of Resources, Schedule, and Outputs/Outcomes of
Recommended PAAs (continued)
NOTE: The preliminary numbers given are estimates based on a general knowledge of the Program
Areas and represent OSW HQ only. Once the Program Areas are fully developed, these estimates may
change. The FTEs listed above are not fully loaded. In addition to the FTE estimates presented above,
the Supervisory FTE for PAAs and coordination of PAAs is estimated at 1.5 FTEs. Overall coordination
of WIN is estimated at 1 FTE. According to estimates, at least 24 person trips will be required over 2
years for Program Implementation and Program Evaluation PAAs.
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SHORT-TERM
PROJECTS
RESOURCES*
SCHEDULE
OUTPUTS/RESULTS
BR and BRS Changes
OSW
2 FTEs for FY 97
1 FTE for FY 98
$700,000 in
extramural funds for
FY97
$200,000 in
extramural funds for
FY98
To be determined
Revised forms; hotline
support for calls; software
developed, implemented,
and documented; training
provided for
regions/states
RCRA Policy Index
System - OSW
0.8 - 1 FTE
$175,000 in
extramural funds for
FY97
Complete by
September 1997
Definition, design
development,
implementation, and
documentation of a
searchable index database
to EPA hazardous waste
program policy
documents
RCRIS Streamlining
OSW
1FTE
$100,000 in
extramural funds for
FY97
1997 RCRIS
Releases
Simplified tracking of
handler status information
obtained from multiple
sources (notification, Part
A, inspection); continued
improvement in national
reports (i.e., permitting
PARS); and modifications
to support FY 1998/1999
national reporting
requirements
Access to RCRIS/BRS
National Data - OSW
0.5 FTE
$200,000 in
extramural funds for
FY97
FY97
Develop shadow national
databases in Oracle for
RCRIS and BRS national
oversight databases
RCRA Docket
Indexing Systems -
OSW
0.2 FTE
$50,000 (initially) in
extramural funds for
FY97
September 1997
Feasibility study that
determines the type and
scope of the database and
index that would serve the
needs of the docket and
its users
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SHORT-TERM
PROJECTS
RESOURCES*
SCHEDULE
OUTPUTS/RESULTS
Exhibit 7-2 Preliminary Estimates of Resources, Schedule, and Outputs/Outcomes of
Recommended Short-term Projects
Special Analyses -
OSW
Enforcement Sensitive
Definitions - OECA
Sector-Based Tracking
-OECA
Compliance Assistance
-OECA
0.5 FTE
$50,000 per year for 2
years
0.1 FTE
5 FTE
$150,000 in
extramural funds for
FY97
$150,000 in
extramural funds in
FY98
To be determined
FY97
FY98
To be determined
FY 97 and FY 98
FY97
Technical documents
identifying relationship
and impact of Agency
proposals or RCRA
information needs and
systems
To be determined
Release of Sector
Indexing Project in
Spring 1997. Public
response and comment
through October 1997
Five Compliance Centers
to be opened in FY 97
Exhibit 7-2 Preliminary Estimates of Resources, Schedule, and Outputs/Outcomes of
Recommended Short-term Projects (continued)
* NOTE: The preliminary figures given are estimates based on a general knowledge of the short-term
projects. Once the projects are fully developed, these estimates may change. The FTEs hi the exhibit are
not fully loaded. An estimated 0.5 FTE will be required for the supervision of project performance and
for coordination of OSW short-term projects. According to estimates, at least 4 person trips over one
year will be required for OSW projects.
7.3.4 Issues to be Addressed by EPA and States
[Reserved pending outcome of further discussions with states]
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