»EPA
United States
Environmental Protection
Agency
Office of
Solid Waste
EPA530-R-99-017
July 1999
Program Evaluation
Program Area
Analysis
Final Report
WIN/INFORMED
-------
This page left intentionally blank.
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY i
DOCUMENT ORGANIZATION 1
CHAPTER 1: INTRODUCTION 3
CHAPTER 2: PROCESS 7
CHAPTER 3: KEY FINDINGS AND RECOMMENDATIONS 11
CHAPTER 4: STABILITY ANALYSIS 41
CHAPTER 5: FUTURE DIRECTIONS 45
APPENDIXA: RECOMMENDED DATA ELEMENT LIST A-l
APPENDIXB: LIST OF ACRONYMS B-l
APPENDIX C: ESC POSITION ON PE RECOMMENDATIONS C-l
LIST OF FIGURES
Figure 1. Major Issues and Activities Covered by Each Program Area 4
Figure 2. PE PAA Scope 6
Figure 3. PE Interview Schedule 8
Figure 4. Recommended Data Elements for Planning, Evaluating, and Reporting the
Accomplishments of the Hazardous Waste Management Program for the
National System 14
Figure 5. Example Input Screens for Performance Accomplishments Tracking System 20
Figure 6. Example Report Output from a Performance Accomplishments Tracking
System 21
Figure 7. Example Report Output from a Performance Accomplishments Tracking
System 22
Figure 8. Summary of System Requirements Related to Hazardous Waste Management
Grants 24
Figure 9. Example Screens for a Grant Related Information System 26
Figure 10. Timeline of the OSWRIP andBYP and OECAMOA 33
Figure 11. System Requirements Related to the Distribution of Guidance 34
Figure 12. Hazardous Waste Management Plans 36
Figure 13. Relationships of National, Regional, and State Hazardous Waste Management
Plans 39
vu
-------
This page left intentionally blank.
VI
-------
DOCUMENT ORGANIZATION
This document is organized into an Executive Summary and the following seven sections:
• Chapter 1: Introduction • Appendix A: Recommended Data
• Chapter 2: Process Elements
• ChapterS: Key Findings and • Appendix B: List of Acronyms
Recommendations • Appendix C: ESC Position on PE
• Chapter 4: Stability Analysis Recommendations
• ChapterS: Future Directions
Chapter 1: Introduction - Identifies the background, purpose, scope, and intended audience of the
Program Evaluation Program Area Analysis (PE PAA).
Chapter 2: Process - Delineates the technical approach the PE PAA Team (Team) used in
performing the analysis. The chapter identifies the Team members and the U.S. Environmental
Protection Agency (EPA) and state hazardous waste program organizations that participated in
interview sessions.
Chapter 3: Key Findings and Recommendations - Presents the results of the Team's analysis of
information and provides recommendations for improving current systems and processes. This chapter
addresses issues relating to burden reduction, potential process improvements, user requirements, and
specific data and system needs.
Chapter 4: Stability Analysis - Discusses issues that could affect PE PAA findings and
recommendations.
Chapter 5: Future Directions - Addresses the future directions for adopting and implementing the
recommendations given in Chapter 3 of this report.
Appendix A: Recommended Data Elements - Lists recommended data elements, including data
elements that support fulfillment of the Government Performance and Results Act (GPRA)
requirements. These data elements represent the information needed to support the program activities
within the PE PAA scope.
Appendix B: List of Acronyms - Defines the acronyms used in this report.
Appendix C: Executive Steering Committee (ESC) Position on PE Recommendations -
Addresses the ESC State, Regional, OCEA, and OSW positions on the recommendations made in this
report by the PE Team.
-------
This page left intentionally blank.
vui
-------
EXECUTIVE SUMMARY
Waste Information Needs/Information Needs for Making Environmental Decisions (WIN/INFORMED)
is a joint information reinvention project conducted by states and the U.S. Environmental Protection
Agency (EPA). The project will determine how hazardous waste program implementation is changing
and how these changes affect future information needs. To date, the WIN/INFORMED project has
divided the hazardous waste management program into five program areas (PA) for in-depth analyses:
Program Evaluation (PE), Universe Identification (UID), Waste Activity Monitoring (WAM), Handler
Monitoring and Assistance (HMA), and Permitting and Corrective Action (PCA).
This report addresses the results of the PE Program Area Analysis (PAA) and covers information
needs and process improvements associated with planning, grants, and evaluation activities within the
hazardous waste management program. Two states, three EPA regions, and various EPA
headquarters staff from the Office of Solid Waste (OSW) and the Office of Enforcement and
Compliance Assurance (OECA) actively participated in the PE PAA Team (Team). The Team
conducted numerous interviews with states, EPA regions, and EPA headquarters to gather information.
All participating organizations in the PE PAA interviews were consistent in describing how commonly
shared external and internal pressures are influencing their program activities, priorities, and information
needs. Program information needs are being influenced by changing circumstances, such as cross-
media environmental management, the need to demonstrate environmental benefits of regulatory
program activities in a more meaningful manner, the need to account to external audiences about
program conduct, the interest in increased regulatory flexibility, and the evolving state-EPA relationship.
Because of these and other influences and objectives, hazardous waste management programs have
new or additional measures (i.e., outputs, outcomes, and indicators) to track the progress of the
program, as well as new integration needs.
Proceeding with information collected during the interviews, the Team identified seven key findings and
developed recommendations to address each of the findings. This Executive Summary briefly lists the
Team's key findings and recommendations for future action. The reader will find supporting details in
Chapter 3 of the report.
KEY FINDINGS AND RECOMMENDATIONS
The following findings and recommendations are grouped into three categories: data needs, information
systems needs, and business process needs. The Design Team will decide whether to modify an
existing system or construct a new system to meet the information systems needs.
-------
DATA NEEDS
1. States and EPA should agree upon a base set of national data elements that will be used in
national and regional plans, grants, and evaluations, including reports on the
accomplishments of the hazardous waste management program.
RECOMMENDATION
The Team recommends a base set of data elements that EPA and states will use for planning,
evaluating, and reporting the accomplishments of the hazardous waste management program. Figure 4
identifies these data elements (see page 14), and Appendix A provides a detailed listing with data
element definitions. State, EPA regional, and EPA headquarters stakeholders must agree that:
(1) this list of data elements is the minimum set needed for national program planning, grants, and
evaluation purposes,
(2) the data element definitions are accurate, and
(3) the history and owner requirements for each data element are correct.
State and EPA acceptance of the data elements listed in Appendix A denotes agreement that these data
elements are a starting point, representing the minimum information needed to plan, evaluate, and report
the accomplishments of the hazardous waste program. These data will be included in a national
information system, although they may be revised by subsequent PAA Teams. The Team is not
recommending any new data elements to support plans, grants, and evaluations, although certain
Government Performance Results Act (GPRA) measures and baselines are under development.
INFORMA TION SYSTEM NEEDS
2. States and EPA cannot easily track the progress of the hazardous waste management
program or readily relate this progress to evaluation and planning efforts. To accomplish
these objectives, states and EPA specified the need for an automated system to track
program accomplishments.
RECOMMENDATION
The Team recommends use of an automated system designed to track the progress of the hazardous
waste management program. It is the Design Team's responsibility to investigate and design automated
systems recommended by the PAA Teams and accepted by the Executive
-------
Steering Committee (ESC). Such systems will be designed with a holistic view of the overall
WIN/INFORMED Initiative and in accordance with current technical architecture guidelines. It is not the
role of the PE PAA Team to recommend any separate or additional system(s), however, the Team
does recommend that an automated system have capabilities to accomplish the following tasks:
• Track actual accomplishments against goals or milestones
• Accommodate all types of measures of success, including quantitative, qualitative, narrative, and
environmental indicators
• Provide flexibility to enable states, EPA regions, and headquarters program offices to adopt it to
meet their own internal reporting needs
• Provide time-specific reports (e.g., quarterly, fiscal year)
• Aggregate and disaggregate data
• Provide easy data retrieval and report writing
• Provide a variety of high-level reports, charts, and graphics
• Link activities to specific RCRA handlers
• Provide links to other relevant databases to "read" data elements where necessary
3. The current process of hazardous waste grant application, negotiation, and management is
overly burdensome. State, EPA regional, and national hazardous waste managers want a
more rapid, automated grant negotiation and approval process. In addition, states and
EPA regions want the ability to search and retrieve information related to their own and
other grant projects.
RECOMMENDATION
The Team recommends that hazardous waste managers and staff have access to an automated system
that addresses user needs related to the grants process. Among other functions, such a system would
provide (1) on-line negotiation of grant applications and workplans, (2) electronic submittal,
distribution, and approval of grant applications and workplan activities, and (3) on-line access to the
apportionment of grant funds by EPA headquarters to EPA regions and by EPA regions to individual
states. Implementing these recommendations is likely to reduce the paperwork burden for states, EPA
regions and EPA headquarters through more efficient sharing of grant information and rapid access to
draft grant applications and workplans.
The Team believes that Partnership 2000 (see page 24 for a summary of Partnership 2000) meets
many of the needs related to grant administration as identified by PE PAA interviewees. By leveraging
the functionality of Partnership 2000, future design and development resources could be saved and
short-term success for the WIN/INFORMED project realized. The Office of Solid Waste and
Emergency Response (OSWER) currently is considering making grant information, guidance, and
application instructions available through Partnership 2000.
111
-------
4. States and EPA identified several deficiencies in the existing information systems used to
support the hazardous waste management program. These deficiencies impede the use of
information to support program implementation, as well as planning, grants, and
evaluation.
RECOMMENDATION
The Team endorses the efforts to build a new or revised hazardous waste management information
system by migrating the Resource Conservation and Recovery Information System (RCRIS)/Biennial
Reporting System (BRS) from a FOCUS platform to an Oracle platform. Additionally, the Team
recommends that a new or revised hazardous waste information management system address the
specific user needs outlined in Chapter 3, including the following:
• Providing users with desktop access
• Providing users with "hot links" to access other related databases
• Using point-and-click technology
• Making data available on a real-time basis
• Providing the ability to perform ad-hoc queries
Solving redundant data entry
• Keeping pace with regulatory changes and technology improvements
B USINESS PROCESS NEEDS
5. The two national offices representing the national hazardous waste management program
(i.e., OSW and OECA) often have competing priorities. Neither OSW nor OECA ranked
their priorities in the past. Integration and ranking of national priorities would give
managers the ability to plan and implement programs more effectively.
RECOMMENDATION
The Team recommends that (1) EPA headquarters better integrate and interpret OSW and OECA
national priorities for hazardous waste management program, (2) both OSW and OECA review their
national priorities and rank them in order of importance or need, and (3) OSW and OECA continue to
involve states and EPA regions when implementing the previous two recommendations. The Team
acknowledges and supports the efforts already made in this area. For example, OECA and OSW
ranked their programmatic priorities for the FY 2000 operating-year priorities meeting in November
1998. Both offices continue to involve states and EPA regions in their planning and priority-setting
efforts. Finally, OECA and OSW, as well as other program offices, agreed to coordinate when
developing national program guidance.
IV
-------
6. OSW and OECA national guidance documents for the hazardous waste management
program have been issued at different times during the federal fiscal year. States and
EPA regions need these guidance documents to be issued concurrently and made available
in a more timely fashion. This would allow sufficient opportunity for hazardous waste
managers to incorporate national priorities into state and EPA region specific plans.
RECOMMENDATION
The Team recommends that OSW and OECA distribute final program guidance to a wider audience by
April 1. This recommendation concurs with the FY 2000 operating year priorities meeting that also
supports the issuance of draft guidance by February 2 and final guidance by April 1. Partnership 2000
should be considered as a candidate for addressing guidance accessibility needs.
7. States and EPA deal with redundant planning requirements as part of managing the
hazardous waste program. Program staff often do not know how a particular plan is used
and sometimes fail to recognize the value of the plan itself. To be efficient and effective,
planning for the hazardous waste management program should be streamlined. Plans that
are developed always should be used.
RECOMMENDATION
The Team recommends that each organization (i.e., states, EPA regions, and EPA headquarters
program offices) streamline their own hazardous waste management planning process and align their
processes with other plans where possible (e.g., GPRA Annual Plan, grant workplans). The Team also
recommends that each organization requiring another organization to submit a plan review their planning
requirements to determine whether the requirements could be streamlined. The Team specifically
recommends reviewing the need and use of OSW's Beginning of Year Plan (BYP) and OECA's
Memorandum of Agreement (MOA). Finally, where plans are not used, the Team recommends
eliminating the plans.
-------
This page left intentionally blank.
-------
CHAPTER 1
INTRODUCTION
BACKGROUND AND PURPOSE
The United States Environmental Protection Agency (EPA) and the states recognize the importance of
reassessing the information needs of the hazardous waste management program. They established the
Waste Information Needs/Information Needs for Making Environmental Decisions (WIN/INFORMED)
initiative to conduct this reassessment and to design, develop, and/or implement changes to information
management. This effort will make high-quality hazardous waste information more readily available to
EPA, states, and tribes, which can use the data to support more effective implementation of the
hazardous waste program.
The WIN/INFORMED initiative has five phases: planning, analysis, design, construction, and
implementation. States and EPA chose to conduct separate planning phases to capture their own
information needs. Completed in fall 1996, these efforts resulted in the development of Information
Strategy Plans (ISPs). An ISP is designed to identify natural groupings of program functions and
information needs, which are referred to as "program areas."
In their ISPs, both states and EPA identified priority improvements to be made in the information and
the information systems used to support program implementation. Specifically, the state ISP identified
three priority program areas for analysis: Universe Identification (UID), Waste Activity Monitoring
(WAM), and Handler Monitoring and Assistance (HMA). These areas all cover specific program
implementation activities. EPA's ISP included Permitting and Corrective Action (PCA) activities in
their program implementation program area. Additionally, EPA selected Program Evaluation (PE) as a
priority program area. States and EPA agreed to form a partnership to conduct the remaining phases
for the five program areas listed in Figure 1, which addresses Resource Conservation and Recovery
Act (RCRA) activities and issues related to each program area. The WIN/INFORMED Project Plan
(June 10, 1998) provides more detailed information on the overall project.
The Program Area Analysis (PAA) examines each program area in detail, considering the adequacy of
current information and information management procedures relative to identified program activities and
information needs. The end goal of a PAA is threefold: (1) to recommend specific data elements to
track in the recommended automated systems, (2) to identify and recommend automated systems that
will meet the needs of the program area, and (3) to identify process improvements that both streamline
current processes and reduce burden. The purpose of this report is to present the results and
recommendations of the analysis phase of the PE program area, covering plans, grants, and
evaluations.
-------
Figure 1. Major Issues and Activities Covered by Each Program Area
PROGRAM
AREAS
RCRA ACTIVITIES
RCRA ISSUES
Program
Evaluation
Planning
• Annual Plans (e.g., RCRA Implementation
Plan [RIP]/ Beginning of Year Plan [B YP])
• Strategic Planning
• Office of Enforcement and Compliance
Assurance Memorandum of Agreement
(OECAMOA)
Evaluations
• Assessments of state, EPA regional, and
EPA headquarters programs
Grants
• 8001 and 3011 Cooperative Agreements
• Performance Partnership Grant (PPG)
GPRA measures/reporting
BYP vs. Annual Plan
Environmental indicator development and
tracking
National Environmental Performance
Partnership System (NEPPS)
Universe
Identification
Facility reporting
• Notification
• Part A
• Biennial Reports
Handler universe categories
• Generators (e.g., small quantity generators
[SQG], large quantity generators [LQG],
universal wastes)
• Transporters (e.g., hazardous waste, used
oil, commercial)
• Treatment, storage, and disposal facilities
(TSDs)
Regulated unit categorization
Facility Identifier Initiative
Facility location (e.g., latitude/longitude)
Generator definitions
Federal/state definitions of hazardous
waste
Definition of solid waste
Universe issues (e.g., used oil)
Standard Industrial Classification (SIC
Code)
Waste Activity
Monitoring
Waste monitoring
• Manifest tracking
• Waste minimization activities (e.g., review
waste minimization plans)
• Waste handling onsite
BRS reporting
Government Accountability Office (GAO)
Waste Minimization Issues
Waste Minimization National Plan
Toxics Release Inventory (TRI)
Expansion Proposal
The types of waste units to be tracked
Waste characteristics
RCRA coding system
One-stop reporting
Handler
Monitoring and
Assistance
Enforcement
• Generators, transporters
• Compliance activities
• Generators, transporters
Inspections
• Generators, transporters
Technical assistance
Definition of "in compliance"
Consistent definitions of enforcement
actions
Enforcement Response Policy revisions
Risk information for targeting
compliance/enforcement
Sector-based approach
-------
Figure 1. Major Issues and Activities Covered by Each Program Area
PROGRAM
AREAS
RCRA ACTIVITIES
RCRA ISSUES
Permitting/
Corrective
Action
Permitting/corrective action (CA)
implementation
• Includes permitting, closure, clean
closures, post closure
• CA under permitting, enforcement, and
voluntary
Site-specific risk assessments
Permitting/CA enforcement
Site characteristics
Permits Improvement Team (PIT)
recommendations
Types of permits
Hazardous Waste Identification Rule
(HWIR) Media
Subpart S
Voluntary/alternate authority corrective
actions
SCOPE OF THE PROGRAM EVALUATION PROGRAM AREA
The scope of the PE PAA has evolved over the life of the project. Initially, the scope included
authorization, budget, GPRA program assessments, planning, grants, and evaluation activities for the
RCRA Subtitle C program. As the Team analyzed the effects of including a large number of waste
management activities, they refined the scope to focus on activities with the greatest national significance
and to pursue efforts that would ensure effective and efficient completion of the project within the
schedule and the resources allocated. The final scope of the PE PAA includes three major subject
areas: plans, grants, and evaluations. Figure 2 provides definitions and examples of these three areas.
INTENDED A UDIENCE
The intended audience for this report is state, EPA regional, and EPA headquarters hazardous waste
program managers and the WIN/INFORMED ESC. The report is designed to communicate an overview
of results of the PE PAA, including the specific data requirements related to hazardous waste program
plans, grants, and evaluations. This report also conveys general recommendations for managing
information more effectively (e.g., user system requirements) and identifies potential process
improvements for hazardous waste program activities related to plans, grants, and evaluations.
More detailed data requirements, such as identification of relationships between groups of data, are
available in the technical support documentation intended for the PE Design Team. The PE Design
Team is responsible for determining what, if any, information systems will be developed to address the
data and system requirements included in this report.
-------
Figure!. PE PAA Scope
PROGRAM
EVALUATION
PLANS
Documents that identify the
vision and intentions of organizations
for implementing hazardous waste
management programs
• Strategic Plan
• RCRA Implementation Plan (RIP)
• BYP Guidance and Submission
• GPRA Annual Performance Plan
• Multi-Year Permitting and
Corrective Action Plan
• Performance Partnership
Agreement (PPA)
• Overarching Memorandum
of Agreement (OMOA)
• Operating Plan
• Office of Enforcement and
Compliance Assurance (OECA)
MOA Guidance
GRANTS
Vehicles used to obtain monies
from EPA to implement
hazardous waste management
programs
3011 Cooperative Agreement
8001 Cooperative Agreement
PPG
EVALUATIONS
Measurements of the output and
effectiveness of hazardous waste
management programs and
program activities
Office of Solid Waste (OSW)
Review of Regions
OECA Review of Regions
Performance Measures
Evaluation
GPRA Program Evaluation
Regional Review of State
State Plan Evaluation
Timely and Appropriate
Enforcement Reports
RECAP
PARS
-------
CHAPTER 2
PROCESS
TEAM ORGANIZATION
A multi-organizational team that included hazardous waste program subject matter experts from states,
EPA regions and EPA headquarters Office of Solid Waste (OSW) and Office of Enforcement and
Compliance Assurance (OECA) had responsibility for completing the PE PAA. The Team consisted
of the following individuals:
• Lillian Bagus, EPA OSW (co-lead)
• Leslie Brennan, New York Department of Environmental Conservation (co-lead)
• Phyllis Donahue, EPA OECA
• Harriett Jones, EPA Region VII
• David Langston, EPA Region IV
• Trisha Mercer, EPA OSW
• Anne Price, Oregon Department of Environmental Quality
• Dina Villari, EPA OSW
The Team was intended to serve as a representative sample of the overall RCRA community.
Interviews with the Team and their home organizations were the primary source of information for the
PE analysis. The recommendations contained within this document are based on the information
collected during these interviews. A three-level process was used as a quality control mechanism for
this report and associated data element recommendations. First, the Team reviewed the accuracy of
interview recordings, subsequent report results, and Team recommendations. Second, broader input
was sought through a critical review of the draft report. The critical review, conducted in July 1998,
sought input from RCRA program and information management staff within EPA Headquarters' OECA
and OSW, 6 EPA regional offices, 10 state RCRA program offices, and the WIN/INFORMED CC.
Third, in September 1998, a second draft of the report was widely distributed in a national review. The
reviewers included both RCRA program and information management staff within EPA Headquarters'
OECA and OSW, 9 EPA regional offices, 22 states, and the WIN/INFORMED CC.
TECHNICAL APPROACH
The entire WIN/INFORMED project is using a standard methodology called Information Engineering
Methodology (IEM) to analyze, design, and implement information management systems for the
hazardous waste management program. For the PE analysis, IEM provided a framework for collecting
and analyzing information on the plans, grants, and evaluations portions of the hazardous waste
management program. The Team's job was to determine, through interviews with program staff and
managers what types of activities related to plans, grants, and evaluations are performed in the program
and what information is needed to support these activities. Activities performed within the program and
the information needed for those activities should drive the development of information systems. In
addition to identifying specific data elements, the ESC instructed the Team to identify processes in the
-------
program that could be improved. This part of the analysis extended beyond the traditional data needs
of the program and focused on actual program processes (e.g., the planning process). The
recommendations included in this report are based on the findings developed by the Team through the
analysis of information collected during program interviews.
The centerpiece of the PAA project and the foundation for the development of this report and the data
and activity model was the series of interview sessions with Team member states, EPA regions, and
EPA headquarters, as listed in Figure 3. Several of the states and EPA regions invited additional state
and EPA regional hazardous waste program experts from nearby organizations to participate in the
interview sessions (e.g., EPA Region IV invited Georgia representatives to participate).
Figure 3. PE Interview Schedule
ORGANIZATION
New York Department of Environmental Conservation
EPA Region II
EPA Region VII
EPA Region IV
Georgia Department of Natural Resources
Oregon Department of Environmental Quality
EPA Region X
EPA Office of Solid Waste and Emergency Response
(OSWER)
EPA RCRA GPRA Team
EPA OSW Communications, Information, and Resource
Management Division (CIRMD)
EPA OSW Permits and State Programs Division (PSPD)
EPA Region V
Wisconsin Department of Natural Resources
Illinois Environmental Protection Agency
EPA OECA
LOCATION
Albany, NY
Kansas City, KS
Atlanta, GA
Portland, OR
Arlington, VA
Arlington, VA
Arlington, VA
Arlington, VA
Chicago, IL
Washington, DC
DATE(S)
9/29/97 - 10/3/97
10/6/97 - 10/10/97
10/27/97-10/31/97
11/3/97- 11/7/97
12/4/97
12/5/97
12/10/97
12/11/97
1/12/98 - 1/16/98
1/27/98 - 1/30/98
-------
Hazardous waste program experts from each organization participated in one often interview sessions.
Each session lasted from one to five days depending on the organization's size, complexity, and
availability of staff. In all cases, the Team attempted to include staff from several organizational levels
ranging from program staff to senior management to secure the broadest representation of the types of
activities performed and the information needed for hazardous waste management plans, grants, and
evaluations. These interviews had the participants identify the following:
• Why and how the hazardous waste programs use information related to plans, grants, and
evaluations
• The information systems currently used to support plans, grants, and evaluations
• The adequacy of the current information and information systems
• Where information needs are not being met
• How information needs are changing or may change in the future
• What types of system functions are needed to support future hazardous waste program activities
related to plans, grants, and evaluations
Additionally, participants provided detail on these issues:
• Benchmarking: exemplary programmatic practices. An example is Oregon's effort to consolidate
planning activities.
• Process Improvements: suggestions for new or modifications of current programmatic processes
to increase efficiency and cost-effectiveness. An example is the recommended synchronization of
EPA planning guidance documents.
• Reporting Burden Reduction: suggestions for decreasing the workload associated with entering
data into existing information systems and reporting to EPA regions and/or EPA headquarters. An
example is eliminating any duplicate data reporting requirements between the BYP and the MO A.
• User Requirements: necessary system technology or functionality that users need to complete
their job. Examples include desk-top access to data and on-line query capabilities.
• National Data: suggestions for the data needed to be shared nationally (i.e., beyond an EPA
regional and state pair) on a consistent basis. This includes data that support the basic
implementation of the program and data that need to be shared consistently between states and
EPA regions to implement the program. An example of national data is "core measures", reported
by states to EPA.
-------
The data on which this document and the technical support documentation are based have been
reviewed by the participating organizations for accuracy. After each interview session, the Team
drafted detailed session summaries for review by the participants in that session. The summaries were
revised based upon participant comments.
Following completion of all interview sessions, the Team analyzed the collected information and
developed the findings and recommendations covered in this report. The findings and
recommendations address the specific set of information (i.e., data elements) needed to perform plans,
grants, and evaluation activities in the hazardous waste management program, the system support
needed to enhance those functions (e.g., the tracking and accountability system), a list of specific user
needs that apply to any new system in the hazardous waste management program (e.g., desk-top
access), and the process improvements needed to better implement the plans, grants, and evaluation
activities within the hazardous waste management program (e.g., streamline the planning process).
10
-------
CHAPTER 3
KEY FINDINGS AND RECOMMENDATIONS
This chapter highlights the key findings and recommendations of the PE PAA. These results, based on
concerns raised during the PE PAA interviews, focus on information management needs and process
improvements related to plans, grants, and evaluations. As noted in Chapter 2, the Team asked
interview participants to address the issue of burden reduction. This request included suggestions for
decreasing workloads associated with reporting to EPA regions and/or headquarters, as well as
entering data into existing information systems. Rather than address burden reduction as a separate
issue, the Team addressed burden reduction within each of the relevant discussions in this chapter.
During the interview sessions, state, EPA regional, and EPA headquarters participants raised issues
related to current program information needs within the scope of other WIN/INFORMED program area
analysis efforts. This report does not address these issues. The WIN/INFORMED CC will brief other
WIN/INFORMED program area teams on the findings and issues that affect their program areas.
Interviewees also raised certain programmatic or policy issues that were deemed beyond the scope of
the PE PAA. For example, interviewees viewed requirements associated with GPRA and NEPPS as
incompatible, with GPRA requiring specific accountability and NEPPS offering broad flexibility.
Because such programmatic or policy issues are not within the scope of this analysis effort and are
being addressed in other fora, the Team did not analyze whether these issues were well founded and
did not develop recommendations on how to address these concerns.
The WIN/INFORMED project identified the need for a culture change in information identification,
collection, and management for the hazardous waste program. The Team determined that a change in
culture is needed in these three ways:
(1) Make information management a high priority.
(2) Assume responsibility as data owners. Accurate and complete data and information are critical to
sound decision making, especially in science-based organizations. It is our responsibility to ensure
the quality of information needed to make decisions and implement the hazardous waste
management program.
11
-------
(3) Integrate program and information management. Currently, there often is a division of duties
between information management and development and implementation of the program. In many
cases, hazardous waste program staff develop regulations and guidance without effectively
consulting with information technology staff. Information management cannot be the sole
responsibility of the information technology staff. Hazardous waste program staff must participate
as knowledgable and vested partners.
The remainder of this chapter is divided into three categories of findings and recommendations: data
needs, information system needs, and business process needs. The data needs category includes the
Team's findings and recommendations related to establishing a base set of data elements for hazardous
waste management program plans, grants, and evaluations. The information system needs category
includes the Team's findings and recommendations on developing and/or adopting automated
information systems for program plans, grants, and evaluations. This category also presents a
discussion of the generalized issues related to the current systems supporting the hazardous waste
management program. Finally, the business process needs category includes the Team's findings and
recommendations on specific process issues integral to the implementation of the hazardous waste
program.
DATA NEEDS
1. States and EPA should agree upon a base set of national data elements that will be used in
national and regional plans, grants, and evaluations, including reports on the
accomplishments of the hazardous waste management program.
PE PAA interviewees agreed that a base set of defined data elements should be used for plans, grants,
and evaluations, including reporting the accomplishments of the hazardous waste management program.
Interviewees further agreed that this set of data elements should be kept to the absolute minimum to
ease the burden of reporting and tracking requirements. Interviewees also suggested that the Team
identify both the current and/or future use of each recommended data element. They believed this
would facilitate the elimination of unnecessary and burdensome collection of data that are not and will
not be used to fulfill program planning and evaluation needs. Additionally, the CC required that each
PAA Team identify or develop definitions for any data elements the PAA Team recommends. The
Team identified how/where the data element currently is used or is expected to be used and whether
states and EPA regions are expected to establish projected commitments (e.g., EPA regions will
inspect eight percent of the large quantity generator universe) or report accomplishments after the fact.
12
-------
RECOMMENDATIONS
Based on the interviews, the Team recommends a base set of data elements that EPA and states will
use for planning, evaluating, and reporting the accomplishments of the hazardous waste management
program. Figure 4 identifies these data elements and Appendix A provides a detailed listing with data
element definitions. State, EPA regional, and EPA headquarters stakeholders must agree that:
(1) this list of data elements is the minimum set needed for national program planning, grants, and
evaluation purposes,
(2) the data element definitions are accurate, and
(3) the history and owner requirements for each data element are correct.
The hazardous waste programs currently report and track each of the recommended data elements.
The Team is not recommending any new data elements to support plans, grants, and evaluations,
although certain GPRA measures and baselines are under development.
In choosing data elements to comprise this minimum set, the Team tried to limit the elements to those
mandatory elements already reported by states and EPA regions through BRS or RCRIS. While these
comprise the majority of the list, there also exist data elements used by EPA to satisfy GPRA
accountability requirements (e.g., reduction in PBT chemicals in waste streams). Because the data
elements represent only the minimum information needs for the national hazardous waste management
program in the planning, grants, and evaluation area, organizations (EPA headquarters, EPA regions,
and states) may have additional specific information needs related to plans, grants, and evaluations
outside of the data elements identified here. For example, states and EPA regions may wish to track
regional/state initiatives or states may have state-only initiatives such as voluntary clean up actions which
must be tracked but aren't necessarily federally reported. In the case of EPA Headquarters, OSW will
be adding those GPRA measures associated with Subtitle D in order to consolidate reporting of waste
program progress. The information system recommended in Finding 2 of this chapter is structured with
the ability to accommodate additional data elements as needed.
The Team expects that the identified data elements might change as the subsequent implementation
PAAs are conducted and issues are further discussed among states and EPA. In the long term, the
Team recognizes that the list of data elements will evolve as program priorities change, new evaluation
measures are developed, and relationships among stakeholders change. The state and EPA
acceptance of the data elements listed in Appendix A denotes agreement that these data elements are a
starting point for a national hazardous waste management information system.
13
-------
Figure 4. Recommended Data Elements for Planning, Evaluating, and Reporting the
Accomplishments of the Hazardous Waste Management Program for the National System
RCRIS Data Elements
GPRA Corrective Action Baseline
RCRA Facility Assessment (RFA) Completed
Notice of Contamination
Determination of Need for a RCRA Facility Investigation (RFI)
Corrective Action (CA) Prioritization
RFI Imposition
RFI Workplan Approved
RFI Report Approved
Referred to a Non-RCRA Authority
Stabilization Measures Evaluation
CMS Imposed
CMS Workplan Approved
CMS Approved
Decision on Petition for No Further Action
Date for Public Notice on Proposed Remedy
Date for Remedy Selection (CM Imposed)
Corrective Measures Design Approved
Corrective Measure Implementation (CMI) Workplan Approved
Determination of Tech Impracticability
Certification of Remedy Completion
Stabilization Measures Implemented
Stabilization Construction Completed
Human Exposures Controlled Determination (GPRA)
Release to Groundwater (GW) Controlled Determination (GPRA)
CA Process is Terminated
Plan Received - Closure
Plan Approved - Closure
Receive Closure Certification
Closure Verification
GPRA Hazardous Waste Controls/Permits Baseline Universe
Part A Submitted
Part A Determination
Process Determination
Part B Call-In
Pre-Compliance Certification Submitted
14
-------
Figure 4. Recommended Data Elements for Planning, Evaluating, and Reporting the
Accomplishments of the Hazardous Waste Management Program for the National System
(continued)
RCRIS Data Elements (continued)
Pre-Compliance Certification Review Completed
Notification of Compliance Testing
Case-By-Case Compliance Extension Requested
Loss of Interim Status (LOIS)
Case-By-Case Extension Granted
Part B Received
Notification of Automatic Extension
Compliance Certification Submitted
Compliance Certification Review Completed
Compliance Extension Expires
Trial Burn Conducted
Public Notice
Final Determination (Operating Permit)
GPRA Hazardous Waste Controls/Post-Closure Permits Baseline Universe
Post-Closure Part B Call-In
Post-Closure Part B Received
Public Notice
Final Determination (Post Closure Permit)
Plan Received - Closure/Post-Closure
Plan Approved - Closure/Post-Closure
Receive Closure Verification
Closure Verification
Verbal Informal Enforcement Action
Written Informal Enforcement Action
Combination-Informal Enforcement Action
Initial 3008(a) Compliance Order
Initial Imminent Hazard Order
Initial Monitoring and Testing Order
Initial 3008(h) Interim Status Corrective Action Orders
Notice of Non-Compliance
Combination-Initial Formal Enforcement Action
Final 3008(a) Compliance Order
Final Imminent Hazard Order
Final Monitoring and Testing Order
Final 3008(h) Interim Status Corrective Action Orders
15
-------
Figure 4. Recommended Data Elements for Planning, Evaluating, and Reporting the
Accomplishments of the Hazardous Waste Management Program for the National System
(continued)
RCRIS Data Elements (continued)
Federal Facility Compliance Agreement
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 106 Order
CERCLA 104 Order
Combination-Final Formal Enforcement Action
Referral to Attorney General
Referral to Department of Justice
Referral to District Attorney/County Attorney
Combination-Judicial Referral
Civil Action for Compliance
Civil Action for Imminent Hazards
Civil Action for Compliance with Previously Issued Action
Civil Action for Interim Corrective Action
Civil Action for Monetary Penalties
Combination-Civil Actions
Consent Decrees
Judicial Orders
Criminal Actions
State to EPA
EPA to State
EPA RCRA to EPA CERCLA
Federal Facility Referral to EPA Headquarters
Combination-Administrative Referral
Date of Enforcement Action
Date of Evaluation
Corrective Action Oversight Inspection
Case Development Inspection
Compliance Evaluation Inspection
Comprehensive Groundwater (GW) Monitoring Evaluation
Compliance Schedule Evaluation
Financial Record Review
RCRA CEI Performed with Screening Checklist
Comprehensive and Coordinated Inspection with CEI
Detailed Multimedia Inspection with CEI
16
-------
Figure 4. Recommended Data Elements for Planning, Evaluating, and Reporting the
Accomplishments of the Hazardous Waste Management Program for the National System
(continued)
RCRIS Data Elements (continued)
Multimedia Screening Checklist Only
Non-Financial Record Review
Operation and Maintenance Inspection
Other Evaluation
Determined Not to Be a Significant Non-Complier
Determined to Be a Significant Non-Complier
Sampling Inspection
Compliance Assistance Activity
Facility Self Disclosure
Area of Violation
Date Violation Determined
Actual Resolved Date
Scheduled Response Date
SEP/Enforcement Milestone Code
Type of Penalty Amount Indicator
Penalty Amount
Multimedia Code
BRS Data Elements
Waste Quantity Unit of Measure
On-Site Handling
Off-Site Handling
Quantity Generated Current Year
Generator Status
Reduce persistent, bioaccumulative, and toxic (PBT) chemicals in hazardous waste streams; baseline
17
-------
Figure 4. Recommended Data Elements for Planning, Evaluating, and Reporting the
Accomplishments of the Hazardous Waste Management Program for the National System
(continued)
Other Data Elements
GPRA enforcement and compliance assurance facility baseline
GPRA enforcement and compliance assurance high priority areas baseline
GPRA enforcement and compliance assurance small business baseline
GPRA enforcement and compliance assurance use of incentives policies
GPRA enforcement and compliance assurance use of PPAs
Increase amount of hazardous waste safely recycled; baseline
Reduce combustion emissions; baseline
INFORMA TIONSYSTEMS NEEDS
2. States and EPA cannot easily track the progress of the hazardous waste management
program or readily relate this progress to evaluation and planning efforts. To accomplish
these objectives, states and EPA specified the need for an automated system to track
program accomplishments.
The hazardous waste program activities performed by states and EPA often support multiple priorities
set internally or imposed externally. States and EPA increasingly are required to track
accomplishments to demonstrate accountability and progress against specific goals. Generally, each
organization has internal goals or milestones and requires tracking and reports of progress toward
meeting those goals or milestones. States and EPA regions negotiate grant commitments and track
accomplishment of these commitments. Under GPRA, EPA has to report annual progress to Congress
and consider current progress when revising strategic plans and developing annual plans. Some state
legislatures have imposed similar requirements (e.g., setting goals, tracking accomplishments, and using
the results in future planning efforts). Several states also publish state of the environment reports.
PE PAA interviewees want a way to determine program performance more easily and quickly.
Program performance results would be used for internal program management and planning and for
reporting accomplishments to a partner organization (e.g., EPA regions to EPA headquarters, states to
EPA regions, grantees to grantors) and to the public. The reports for each of these audiences would
contain different levels of information and would use different formats.
18
-------
For instance, a state may decide to use the system to manage its program internally and to report to the
EPA region. The state may need to add to or delete from its set of internal reporting data to report to
the EPA region. Internal reports may include technical jargon or data not useful to the public, while bar
charts or other graphics used for public reporting may not be specific enough to support program
planning and management. Because of these different uses and audiences, an automated system should
have the capability to aggregate and disaggregate data and provide a variety of high-level and detailed
reports, charts, and graphics.
Program accomplishments can be quantitative (e.g., nine permits issued, emissions reduced by 50
percent) or narrative (e.g., rule promulgated). Both states and EPA are trying to move from activity
counts (e.g., 14 technical assistance visits completed) to indicators of environmental progress (e.g.,
decrease in cancer cases). Interviewees indicated the system should have the capability and flexibility
to accommodate these various types of measures, including goals, milestones, and actual
accomplishments. In addition, some interviewees want to link their work plan activities to specific
RCRA handlers, as appropriate (e.g., nine inspections performed at nine specific facilities).
Interviewees want the system to accommodate measures for pollution prevention and RCRA Subtitle
D.
Some interviewees want the ability to avoid duplicate data entry and recommend that a system meeting
these needs have direct links to other databases, such as TRI, RCRIS (if the Design Team decides a
separate system is appropriate), and BRS, to "read" relevant data elements pertinent to the program
area. Finding 4 of this chapter also addresses this capability.
RECOMMENDATIONS
The Team recommends an automated system designed to meet these objectives:
• Track actual accomplishments against goals or milestones
• Accommodate all types of measures of success, including quantitative, qualitative, narrative, and
environmental indicators
• Provide flexibility to enable states, EPA regions, and headquarters program offices to adopt it to
meet their own internal reporting needs
• Provide time-specific reports (e.g., quarterly, fiscal year)
• Aggregate and disaggregate data
• Provide easy data retrieval and report writing
19
-------
• Provide a variety of high-level reports, charts, and graphics
• Link activities to specific RCRA handlers
• Provide links to other relevant databases to "read" data elements where necessary
A system with these capabilities would give hazardous waste managers at all levels the ability to
determine program performance more easily, regularly, accurately, and effectively. States and EPA
could use the results for internal program planning and management, reporting purposes, and public
education. Figures 5, 6, and 7 provide example reports and screens that might represent the types of
information wanted by PE PAA interviewees.
Figure 5. Example Input Screens for Performance Accomplishments Tracking System
Plan Name > 1 | ^ 2|
Effective Start Date > | | Effective End Date >l 1
Status -> I 1 W 3 1
W Indicates pull -down menu will be available for user selection and/or
customization. Examples follow:
Ti . T2 T3
Region 1 HW Beginning of Year Plan T. ft
Management Division Enforcement MOA ^™\
Region 2 Enforcement Workplan
Dlvlslon Multi -Year PCA Plan
™S??TO GPRA Annual
ObW AlB Performance Plan
PprinH Start DatpJ
Oiiantitativp Taropt J
Qualitative Target ;
Y!
T2
1 Period End Date =1
1 Quantitative Actual :
Qualitative Actual :
Narrative >
Description of
other program
^V Indicates pull-down menu will be available for user selection and/or
* customization. Examples follow:
Y 1 Closures V 2 closure plan approvai
Operating permits Operating permit final
Corrective action determination
Combustion Groundwater releases controlled
emissions Combustion emissions reduced
Public Informed ...... ,
20
-------
Figure 6. Example Report Output from a Performance Accomplishments Tracking System
25 n
Completed 1997 After 1997
Through Projections
1997
Year
IstQtr 2ndQtr 3rd Qtr 4th Qtr
Quarter
Region IV Percent of Total Inspections, by State
(example data only)
Mississippi
33%
Alabama
14% Florida
4%
Georgia
17%
Kentucky
7%
D Alabama
B Florida
D Georgia
D Kentucky
D Mississippi
B North Carolina
B South Carolina
D Tennessee
Number of
Inspections
Quarter
21
-------
Figure 7. Example Report Output for a Performance Accomplishments Tracking System
US EPA RCRA Program
FY 98 GPRA Accomplishments Report
Region: All
Performance
Measure
Measure
Type
Baseline
Current Year
Targets
FY98
Actual
Percent of
Targets
1. Control releases - Key
municipal solid
waste landfills
2. Reduce Key
combustion
emissions
3. Reduce PBT Key
chemicals in
hazardous waste
streams
4. Inspect LQG Key
Universe
3,536 Municipal Solid
Waste Landfills
1994 hazardous waste
combustor emissions of
dioxins/furans, particulate
matter, and acid gases
1991 GPRA Baseline
1250
370
50%
8%
1201
300
96.1%
81.0%
8%
100%
The development of a program accomplishments tracking system will meet the planning needs of some
organizations and will be less burdensome than current planning requirements. For instance, if EPA
regions use the program accomplishments tracking system to enter projected and actual
accomplishments of the hazardous waste management program, OSW may determine that certain
components of the BYP are no longer needed.
If this recommendation is approved and supported by the ESC, the Design Team, working with PE
PAA Team members, will decide whether to design and construct a separate system or to modify an
existing system to address the above recommendations. The Design Team also will determine how to
address each of the above recommendations. For example, the Design Team will address quality
assurance issues when determining the feasibility of links to other databases.
22
-------
3. The current process of hazardous waste grant application negotiation and management is
overly burdensome. State, EPA regional, and national hazardous waste managers want a
more rapid, automated grant negotiation and approval process. In addition, states and
EPA regions want the ability to search and retrieve information related to their own and
other grant projects.
Currently, grant negotiation and application is a manual process. Comments and responses to
comments on state grant workplans, including the negotiation of work activities, typically are
communicated through a series of telephone conversations, letters sent through the U.S. Postal Service,
the Internet, and/or face-to-face meetings. This approach causes state, EPA regional, and national
hazardous waste managers to spend a significant amount of resources and time negotiating and finalizing
grant applications and workplans. The negotiation of workplans is an essential process, and the
automation of this process can make it more efficient.
During the PE PAA interview sessions, states and EPA regions indicated an interest in negotiating EPA
grants (i.e., 3011, 8001, and PPG) electronically, including the ability to enter and track grant
application information and workplans more easily and efficiently. Interviewees also want the ability to
negotiate workplan activities by commenting on drafts and responding to comments in an automated
manner. Although this can be accomplished via electronic mail, users believe that a grant-specific
framework for automating the negotiation process would require fewer resources and less time. Such a
framework would support a more uniform and organized process that also allows for "tickler"
notifications, electronic signature, movement of the grant application through the necessary processes,
notification of grant award, and interfacing with other EPA grant and financial systems.
In addition to automating the grant negotiation process, interviewees specified the need to search and
retrieve grant information by issuing organization, keyword, location, or media. These capabilities
would give a tribe, state, EPA region, or other organizational unit the opportunity to learn about grant
projects and programs being implemented around the country. Some interviewees want to view listings
of all federal grant programs applicable to the hazardous waste management program, perhaps by
having "hotlinks" to specific websites offering this information. This capability would be especially
helpful for organizations that have resource constraints and are seeking alternative financial assistance.
Finally, some states expressed interest in having on-line capabilities for viewing the apportionment of
grant monies by EPA headquarters to the EPA region and the EPA regional apportionment of grant
monies to individual states. Figure 8 lists all system requirements related to hazardous waste
management grants.
23
-------
Figure 8. Summary of System Requirements Related to Hazardous
Waste Management Grants
• Ability to enter and review grant applicant information
• Ability of grant applicants to complete draft and final versions of applications (e.g., application form) and
attach workplan information
• Ability of grant applicants to establish select user groups to receive draft and final grant applications and
workplans for review and approval
• Ability of grant issuing organization (e.g., EPA region, state) to negotiate grant application
• Ability of issuing organization to review grant application information and indicate the application status
(e.g., approved, denied)
• Ability of stakeholders to access a list of all EPA grants awarded to stakeholders, with the capability of
sorting this information by organizational unit, type, media, fiscal year, awarding organization, and keyword
• Ability to access electronically the apportionment of grant funds by EPA headquarters to EPA regions (not
specific to individual states) and by EPA regions to individual states
• Ability of stakeholders to access a list of all federal grant programs
The Team identified an automated EPA/state pilot system, Partnership 2000, the capabilities of which
appear to address many of the system requirements related to grants as discussed above. Currently,
the system is being piloted in five states and five EPA regions, as well as two EPA headquarters media
offices. Partnership 2000 is a Lotus Notes and Internet based application specifically designed to
reduce the paperwork associated with grants administration. Partnership 2000 allows an electronic
means for all grants processing and communication (such as posting, distribution, and approval between
EPA headquarters, EPA regions and grantees). It also provides an on-line mechanism and central
location for posting and accessing grant-related materials, such as guidance, planning documents, and
final workplans, accommodates the selection of document reviewers and automatic distribution to
selected reviewers, and allows reviewers to transmit comments to a document's author. Partnership
2000 provides the ability to comment on and respond to comments between the grant applicant and the
issuer, as well as the ability to obtain electronic signature approvals for EPA grants. Access to draft
materials and
24
-------
portions of finalized materials (e.g., sensitive budget information) can be limited to specified users. Final
grant applications and workplans can be posted within the system for public use. Users also can search
for and retrieve grant information by type, location, organization, and media1.
RECOMMENDATIONS
The Team recommends that hazardous waste managers and staff have access to an automated system
that addresses user needs related to the grants process, as described above. The capabilities of this
system include providing (1) on-line negotiation of grant applications and workplans, (2) electronic
submittal, distribution, and approval of grant applications and workplan activities, and (3) on-line
access to the apportionment of grant funds by EPA headquarters to EPA regions and by EPA regions
to individual states. Implementing these recommendations is likely to reduce the paperwork burden for
states and EPA through more efficient sharing of grant information and rapid access to draft grant
applications and workplans. Figure 9 shows screens with examples of grant-related information as
specified by users.
The most recent WIN/INFORMED Project Plan specifies system design and development efforts for PE
PAA beginning in winter 2002. The Team, however, recommends that further investigation of the
Partnership 2000 system functionality be considered sooner. The Team believes that Partnership 2000
meets many of the needs related to grant administration as identified by PE PAA interviewees. By
leveraging the functionality of Partnership 2000, future design and development resources could be
saved and short-term success for the WIN/INFORMED project realized. It also should be noted that
Partnership 2000 meets user requirements discussed in Finding 2 of this chapter, further strengthening
the Team's recommendation that this system be considered for use by the hazardous waste
management program.
4. States and EPA identified several deficiencies in the existing information systems used to
support the hazardous waste management program. These deficiencies impede the use of
information to support program implementation, as well as planning, grants, and
evaluations.
PE PAA interviewees identified a number of deficiencies in the current systems' ability to support the
hazardous waste management program. These deficiencies relate to information needs for hazardous
waste management plans, grants, and evaluations and the needs associated
OSWER is considering making grant information, guidance, and application instructions available
electronically through Partnership 2000.
25
-------
Figure 9. Example Screens for a Grant-Related Information System (Source: Partnership 2000)
Grant Application
^ [Document Status | ^ | Estimated Funding |
^ [Submission Information 1 ^ | Application Attachments 1
^ |Applicant Information I ^ | Review |
^ [Project Information 1 ^ | Authorized Representative |
^ |Workplan Information | ^ | Origination Information |
>=>• Click on Icon
M
Grant \ \
Awards J g]
<*2*ta
vu
^\>
Grant Application
and Work pi an
> Click on Icon
1
*
Grant Financial
Status Lookup
^^
r-H ^^
EPAHQ, Regions,
Select workplan [j^/|
reviewers, view
comments, respond
to comments
with all other aspects of implementing the hazardous waste management program. The Team believes it
is important to present these usability problems, even though many of the problems are not specific to
this analysis and have been identified in other RCRIS/BRS fora and reports. Many of the problems
identified here likely will impact future PAA efforts, and some already are being addressed by other
WIN/INFORMED activities (e.g., migration of RCRIS and BRS from a FOCUS platform to an Oracle
platform) and other EPA and state activities.
The primary users of RCRIS and BRS data are state and EPA regional implementers of hazardous
waste management programs, as well as other interested public parties. The Team confirmed user and
ISP findings that the current RCRIS and BRS mainframe Focus databases are difficult to use. In
addition, users are frustrated by the complexity and redundancy of other state, EPA regional, and
national systems that often overlap and sometimes conflict with RCRIS and/or BRS.
26
-------
Users want to continue strong partnerships among state, EPA regional, and EPA headquarters
personnel to address concerns and issues, especially regarding data quality. Users specified that in
some states and EPA regions, as well as at EPA headquarters, there is a lack of effective
communication between program staff and data management staff. To maintain high quality data, users
believe managers must provide sufficient resources so as not to impede the success of any future
system improvements. Program and data management staffs must be trained and provided with
appropriate guidance on working with information systems for the hazardous waste management
program.
Based on PE PAA interviews, RCRIS/BRS users indicated six specific requirements that would make
working with current systems more effective and efficient:
• Users want one access point for linking or retrieving information from hazardous waste
program databases, including external databases that contain information relevant to the
hazardous waste management program. Users indicated a need to have access to relevant
databases from one, central access point, preferably from their desktop. For instance, users need
one access point to information contained in such databases as Dun & Bradstreet, TRI, and
Docket. When EPA regional staff access information on a specific facility through RCRIS, it would
be useful to be able to obtain financial and other information through a link to Dun & Bradstreet.
Users understand that integrating information from multiple systems into a single application can be
technically difficult or impossible to accomplish but believe that providing one point of access to the
more commonly used systems (e.g., RCRIS, BRS, TRI) is feasible, needed, and possible to
achieve with today's technology.
• Users want desktop access through a friendlier system interface, such as point-and-click
technology.2 RCRIS/BRS mainframe FOCUS databases are difficult and time-consuming to use.
Users want a faster, simpler, more efficient method of retrieving and viewing hazardous waste data
from their desktop. To help address this issue, EPA Region I has developed a dBase tool, RCRIS
INFO. While not a point-and-click technology, RCRIS INFO is an electronic report of data
extracted from RCRIS and BRS that can be queried quickly and easily by the user at his or her
desktop. During the interview sessions, the Team found that other EPA regions are using the same
or similar systems or desired to obtain such a system.
In support of the WIN/INFORMED initiative, OSW's Information Management Branch (1MB) currently is
addressing this long-term user requirement. 1MB will migrate RCRIS and BRS from their current software/hardware
platform (i.e., FOCUS on the EPA mainframe) to a new software/hardware platform (i.e., Oracle on a central EPA
UNIX server with a Web browser user interface).
27
-------
Users want hazardous waste program data available on a real-time basis. To make the best
decisions possible, users indicated a need to have real-time data. A real-time data system that all
users could access simultaneously would eliminate the current resource intensive attempts to
reconcile data on reports that were pulled at different times from different levels of hierarchical
databases (i.e., implementer, merge, oversight).
Users want the ability to perform ad-hoc queries to eliminate the inefficiencies associated
with retaining specialized computer services to retrieve data.3 Because of the dynamic nature
of program needs, users often are required to obtain and analyze data in new or different formats.
Users need the flexibility to develop queries on an ad-hoc basis. To accomplish these needs in
EPA Region IV, RCRIS data management staff developed customized reports for users. Although
this approach has achieved a certain level of success, many system users want to perform these
queries themselves. To conduct such studies as trend analysis, users indicated a need to have the
ability to generate graphs, such as bar graphs and pie charts, to display certain types of information.
Additionally, users indicated a need for Geographic Information System (GIS) information related
to demographic, census, and other concerns to support such hazardous waste management
program initiatives as Environmental Justice and Community-Based Environmental Protection.
Users want redundant data entry problems resolved to enhance data quality and save
resources. To eliminate rekeying of information, states with their own systems want to be able to
supply national data (e.g., via flat files or Oracle tables) for loading into a national database. Users
often have to enter the same data into more than one system. For example, EPA regional staff may
be required to enter the same or related data into RCRIS/BRS and Docket databases (e.g., facility
information such as location, facility name, generator status). Even within the same system, users
sometimes must key enter data twice (e.g., entering corrective action orders information into two
separate RCRIS modules). Users want to enter data only once and have the data read by other
systems. For example, some states that have developed their own state systems want to enter data
into their system and have the information "automatically" loaded into the national system (e.g.,
RCRIS/BRS).
Users understand that any system must change and continuously improve. They believe
there is a need to ensure that the change management process allows all users a voice in
changes and balances the need for improvements with the need to maintain stability. Users
have concerns that their needs may not be reflected in decisions to add or eliminate data elements
from existing database systems. Some users have experienced such problems
See footnote number 2 on previous page.
28
-------
in the past and believe that decision makers may have made different decisions if they understood more
completely the consequences of the changes. Consequently, users believe that any system development
effort must continue to include a change management process and that this process must be directly
linked to the processes that result in change to the RCRA program (e.g., regulation development). As
with any new system, all users (state, EPA regions, and EPA headquarters) should receive adequate
training.
RECOMMENDATIONS
The Team endorses the direction currently being taken to build a newly revised hazardous waste
management information system by migrating RCRIS and BRS from a FOCUS platform to an Oracle
platform. The vision as defined by the technical architecture will allow any user that has Internet access
the ability to create, manage, and use RCRA data from their desktop. The Team recommends that the
ultimate new system(s) resulting from the WIN/INFORMED effort address the specific user needs
outlined below:
• Providing users with desktop access
• Providing users with hot links to access other related databases
• Using point-and-click technology
• Making data available on a real-time basis
• Providing the ability to perform ad-hoc queries
• Reducing or eliminating redundant data entry
• Providing a system which keeps pace with regulatory changes as well as system improvements over
time
Recognizing that the EPA ENVTROFACTS system provides selected information from all major EPA
systems (e.g., BRS, RCRIS, TRI, PCS), the Team recommends that user involvement,
communications, and training in ENVTROFACTS be increased. To ensure user involvement in
determining access to other databases, the Team recommends that EPA establish a user group to help
determine what data can be linked from ENVTROFACTS.
In migrating to a new or revised hazardous waste management information system, the Team also
recommends that:
(1) Hazardous waste data users in states and EPA regions be involved in the change process from the
outset and that the process adhere to change management procedures. In doing this, states and
EPA will strengthen their partnership by accommodating user needs at all levels. Priorities for
establishing and implementing a change management process will be based on available funding.
29
-------
(2) The change management process be linked into the processes that result in program change, such
as regulation development. This would better integrate data management with program
implementation and ensure that the changes made within the program can be captured accurately in
the data systems. As with any new system, all users should receive adequate training.
(3) EPA and states develop better communications across the programmatic user community to enable
clearer understanding of how data are used. Additionally, EPA should develop better
communications across the information management user community regarding proposed system
changes as a result of new or changing programmatic direction.
B USINESS PROCESS NEEDS
5. The two national offices representing the national hazardous waste management program
(i.e., OSW and OECA) often have competing priorities. Neither OSW nor OECA ranked
their priorities in the past. Integration and ranking of national priorities would give
managers the ability to plan and implement programs more effectively.
OSW and OECA establish national program priorities that compete for resources and attention. The
difficulty in meeting these goals and objectives with limited resources is compounded by unclarified
ranking of priorities within and between the national program offices. Issuing separate guidances at
different times exacerbates the burden of trying to address all priorities with limited resources. States
and EPA regions both agree that it would be beneficial to receive one set of comprehensive, integrated,
national priorities for the hazardous waste management program that holistically establish the program's
direction.
The issue of resource competition for achieving the goals and objectives of the two offices is a
significant one. An example of competing priorities is illustrated by considering high priority RCRA
facilities (OSW) and sector priorities (OECA). States and EPA Regions may increase the issuance of
formal enforcement action, such as 3008(h), 7003, 3013 orders, and 3008(a) orders, to meet OECA's
Industrial Sector Initiative targets. However, many of the same EPA regional and state staff who work
on issuing these orders also may work on the GPRA corrective action sites, an OSW high priority
activity. An individual's work in one area draws resources away from work in the other. In a second
example, OECA encouraged an increase in enforcement actions, and OSW encouraged an increase in
authorization decisions for FY 1998. The EPA regional legal staff could not address both of these
priorities effectively and decided to focus on one priority.
30
-------
PE PAA interviewees strongly indicated the need for one set of integrated and complementary priorities
with an established ranking for each priority, for the national hazardous waste management program.
The national priorities should be flexible enough to accommodate EPA regional and state priorities.
Interviewees also indicated a need for effective involvement of states and EPA regions in developing
these priorities.
RECOMMENDATIONS
The Team identified three issues in this area. First, priorities have not been ranked within OSW or
OECA (i.e., all priorities are equally important). Second, OSW and OECA national priorities compete
for the same resources and attention. Third, states and EPA regions need to be involved in establishing
national priorities to ensure adequate consideration of current implementation issues and the flexibility to
accommodate state and EPA regional priorities.
The Team recommends that both OECA and OSW review their national priorities for the hazardous
waste management program and rank these priorities in order of importance or need. EPA
headquarters places equal importance on all activities in OECA's MOA and OSW's RTP/BYP. Not
every activity in OECA's MOA and OSW's RTP/BYP can receive the same level of resources and
attention. By ranking these activities, EPA headquarters would provide clearer direction to states and
EPA regions. One way to rank activities would be to use the percent of total resources dedicated to
the activities in EPA's Annual Plan.
The Team recommends that EPA headquarters better integrate OSW and OECA national priorities for
the hazardous waste management program. To accomplish this, OSW and OECA's RCRA
Enforcement Division (RED) could work together to identify and interpret applicable OECA hazardous
waste priorities. OSW then could include this identification and interpretation of priorities into the RIP.
In this way, OSW and OECA could communicate a single, integrated, and complementary set of
national hazardous waste program priorities. The Team acknowledges and supports the efforts already
made in this area. For example, OECA and OSW ranked their programmatic priorities for the FY
2000 operating-year priorities meeting in November 1998. Both offices continue to involve states and
EPA regions in their planning and priority-setting efforts. Finally, OECA and OSW, as well as other
program offices, agreed to coordinate when developing national program guidance.
The Team recommends that OSW and OECA continue to involve states and EPA regions when
implementing the above recommendations and identifying future priorities. Inclusion of these
organizations will strengthen the EPA/state partnership and will ensure that national priorities are
effectively integrated with program implementation activities at the state and EPA regional levels
-------
6. OSW and OECA national guidance documents for the hazardous waste management
program have been issued at different times during the federal fiscal year. States and
EPA regions need these guidance documents to be issued concurrently and made available
in a more timely fashion. This would allow sufficient opportunity for hazardous waste
managers to incorporate national priorities into state and EPA region specific plans.
OSW and OECA have not issued guidance documents for the hazardous waste management program
concurrently and with enough lead time to give states and EPA regions the opportunity to effectively
incorporate national priorities into state and EPA regional plans and agreements. As a result, some
states and EPA regions must revisit plans and negotiated agreements to address newly received
guidance and related priorities. This "revisiting" consumes valuable time and resources. Interviewees
stated that guidance materials should be issued earlier, distributed to a wider audience, and made
available more rapidly because timing issues have a negative impact on state and EPA regional
negotiations and planning efforts.
To better understand the guidance timing issue, the Team analyzed the 1998/1999 schedules of the
OSW RIP and BYP and the OECA MO A. The OSW draft RIP and OSW RIP Final Guidance (as
part of OSWER's final consolidated guidance) were issued in January and March of 1997, the OECA
MO A Draft and Final Guidance were issued in February and June of 1997, respectively, and the OSW
BYP Draft and Final Guidance were issued in June and September of 1997, respectively, as shown in
Figure 10. Although state fiscal years, which in many cases vary from the federal fiscal year and with
other state fiscal years, affect the timing of grant negotiations with EPA regions, most interviewees
agreed that relevant draft guidance documents should be distributed by February and finalized and
distributed by April. Because some states and EPA regions have agreed to operate on state fiscal
years for PPAs, issuance of final guidance by April will not accommodate all state and EPA region
planning needs but will improve the negotiations and planning efforts of some states and EPA regions.
It should be noted OECA and OSWER guidances for FY 2000/2001 are scheduled to be issued by
April 1.
To determine if states and EPA regions generally could rely on draft guidance documents for
developing state and EPA regional plans, the Team compared the draft and final OSW RIP and BYP
and the OECA MO A. For fiscal year 1998/99, there were no substantive changes in the RIP or BYP
draft and final documents. For fiscal year 1998/99, as compared to the draft, the final OECA MOA
added a significant sector (i.e., coal fired power plants), which required some states and EPA regions
to revise plans and/or renegotiate grant activities. Because of substantive revisions from draft to final
documents, states and EPA regions are often reluctant to rely on draft documents.
32
-------
Additionally, PE PAA interviewees believe that guidance documents for the hazardous waste
management program should be distributed more widely to allow for a more comprehensive set of
comments on draft guidance and input on submission documents. For example, states and EPA regions
would like the OECA MOA distributed to regional program personnel in addition to regional
enforcement and compliance assurance personnel. States and EPA regions also stated they would like
to be notified when new guidance documents or updates are issued and distributed. Once finalized,
OSW and OECA should make all final guidance documents electronically available in a timely fashion
in one easily accessible location (see footnote 1 on page 25). While it is the responsibility of regional
enforcement and compliance assurance personnel to appropriately distribute OECA guidance within the
EPA region (e.g., to regional program staff), providing electronic access to draft and final guidance
materials at a national level will ensure that guidance is reaching all who need it within states, EPA
regions, and EPA headquarters.
Figure 10. Timeline of the OSW RIP and BYP and OECA MOA*
FY1 CY1 : 1997
EPA
Headquarters
EPA Regions
State
Environmental
Agencies
OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP
MOA: OECA
discusses
priorities with
regions
MOA:
Regions
provide
OECA with fc
input
FY(98/99)
MOA: States
provide
regions with
input fe.
FY(98/99)
RIP: OSW BYP: OSW BYP: OSW
issues issues Draft issues Final
Final FY(98/99) FY(98/99)
Guidance Guidance Guidance
FY(98/99)
MOA: MOA: OECA MOA:
OECA issues Final OECA
issues Draft FY(98/99) comments
Guidance FY(98/99)
MOAs from
Region
BYP:
Regions
comment on
FY(98/99)
Guidance
MOA:
Regions
submit draft
OECA
FY2 CY2:
OCT NOV DEC JAN
BYP:
Regions
submit FY
(98/99) to
HQ
>fc
*
MOA:
Regions
submit final
FY( 98/99)
MOA to
OECA
* State fiscal years vary. Some states and EPA regions develop plans and agreements to coincide with state fiscal
years.
33
-------
Finally, states and EPA regions want to review
and comment on-line on draft guidance
documents for the hazardous waste
management program. Such a capability will
increase the efficiency of both the guidance
development and distribution process.
Interviewees, predominantly at EPA
headquarters, want the ability to provide
electronic access to specific individuals or user
groups. This would include the capability to
electronically transmit or provide electronic
access for notices of new guidance revisions or
other related information.
RECOMMENDATIONS
Figure 11. System Requirements Related to
the Distribution of Guidance
Ability to electronically transmit draft and final
guidance materials for the hazardous waste
management program, notifications of updates,
and other "tickler" information (e.g., review dates)
to specific users for easier, more rapid reviews and
approval (this could include electronic signature
for approval)
Ability to make guidance materials available
electronically to all stakeholders
The Team recommends that OSW and OECA align the schedules for development and distribution of
the OSW RIP and BYP and the OECA MOA. In accordance with current EPA policy that requires
offices to issue all guidance by April 1, the Team recommends that final hazardous waste management
guidances be distributed by April 1 of the preceding federal fiscal year to give states and EPA regions
the opportunity to better develop plans and agreements (e.g., grant workplans, PPAs) that address
cross-program issues and to allow more rational tradeoffs between programs. Distribution of both
documents by April 1 would serve to promote a holistic approach to regional and state planning efforts.
The Team agrees with and supports the recommendation from the FY 2000 operating year priorities
meeting that supports issuance of draft guidance by February and final guidance by April.
To address the distribution and access needs expressed by PE PAA interviewees, the Team
recommends that draft and final versions of the MOA, RIP, and BYP (1) be sent more rapidly and to a
wider audience of users through an electronic notification system and (2) be posted in an automated
system to provide users with central access to the most current guidance. Both of these
recommendations would result in a more efficient process for commenting on draft guidances, allow
easier and greater access to guidance, and provide OSW and OECA with the ability to distribute draft
and final guidance to targeted reviewers (i.e., select reviewers from a list of system users and distribute
to and receive comments and approvals from these reviewers).
34
-------
As discussed earlier in this report, the Team identified and examined Partnership 2000, an automated
system designed to counter the paperwork-intensive grant administration process. The Partnership
2000 system also offers functional capabilities that appear to meet user requirements related to
distributing and posting guidance, as discussed above. Partnership 2000 allows users to post, search,
and retrieve EPA and state guidance materials using a Lotus Notes platform or an Internet-Web
Browser. The system provides an electronic vehicle for communication, review, and transmittal of
documents, with the additional capability of allowing organizations to target specific users to receive,
review, and approve documents (including electronic signature capabilities). In addition, the system
allows Internet access to guidance materials published and posted by any participating organization.
The Team recommends that Partnership 2000 be considered as a candidate for addressing the
guidance timeliness and accessability needs.
7. States and EPA deal with redundant planning requirements as part of managing the
hazardous waste program. Program staff often do not know how a particular plan is used
and sometimes fail to recognize the value of the plan itself. To be efficient and effective,
planning for the hazardous waste management program should be streamlined. Plans that
are developed always should be used.
During PE PAA interview sessions, the Team found the theme of burdensome planning requirements to
be universal. Within the hazardous waste management program, the process of developing similar
program and implementation plans is perceived to be time consuming, resource intensive, and
unproductive. While interviewees did see a need for establishing a strategic vision for the hazardous
waste management program (i.e., long-term planning) and planning for annual implementation activities
(i.e., short-term planning), they believe that the current planning architecture for managing the hazardous
waste program should be streamlined.
The Team found a large number of hazardous waste management plans, many with overlapping
purposes and contents. The various plans may be required by statute or regulation (e.g., GPRA, grant
workplans), by another unit within an organization (e.g., OECA's MOA, OSW's BYP), or by internal
policy (e.g., Division Operating Plans, Branch Operating Plans). Figure 12 lists the types of hazardous
waste management guidance and plans currently developed by hazardous waste program managers at
the state, EPA regional, and national levels.
Figure 12. Hazardous Waste Management Plans
Name
Strategic Plans
Purpose
A state, regional, or headquarters plan
that provides a high-level description
to provide general direction, priorities,
and goals for a particular program
over a multi-year period.
Frequency
Varies
Organization
Requiring
Plan or Input
EPA HQ, EPA
regions, and
states
Organization
Responsible for
Writing Plan
EPA HQ, EPA
regions, and
states
35
-------
Figure 12. Hazardous Waste Management Plans
Name
RCRA
Implementation
Plan (RIP)
Multi-year
Permitting and
Corrective
Action Plan
Enforcement
MOA Guidance
Enforcement
MOA
Submission
(state response)
Enforcement
MOA
Submission
(EPA regional
response)
Operating Plans
Performance
Partnership
Grant (PPG)
Workplan
Purpose
A guidance developed by OSW for
distribution to EPA regions and states
specifying priority areas of the
hazardous and solid waste
management programs for a 2-year
period.
A state-developed plan describing the
permitting and corrective action
implementation activities at facilities
for a 3-to-5 year period.
A template developed by OECA for
distribution to EPA regions to capture
and identify specific projections and
issues related to the enforcement and
compliance assurance program,
including the hazardous waste
management program for a 2-year
period.
The state response indicating the
state plan related to implementing the
enforcement and compliance
assurance program.
The EPA regional response to the
Enforcement MOA Guidance
indicating the regional projections
related to implementing the
enforcement and compliance
assurance program, including the
hazardous waste management
program, for a 2-year period.
Plans that describe the waste
management implementation activities
of an organization for a specified
period of time.
Plan indicating state projections and
activities to be accomplished with
financial support during the
cooperative agreement period.
Frequency
Biannual
Varies
Biannual
(updates
during the
off years)
Annual
Annual
Varies
Varies
Organization
Requiring
Plan or Input
EPA OSW
EPA regions
EPA OECA
EPA regions
EPA OECA
EPA OSW,
EPA regions,
and states
EPA regions,
states
Organization
Responsible for
Writing Plan
EPA OSW
EPA regions and
states
EPA OECA
States
EPA regions
EPA OSW, EPA
regions, and
states
States
36
-------
Figure 12. Hazardous Waste Management Plans
Name
GPRA Annual
Performance
Plan
Overarching
MOA (OMOA)
Performance
Partnership
Agreements
(PPA)
Beginning of
Year Plan (BYP)
Guidance
Beginning of
Year Plan (BYP)
Submission
Cooperative
Agreement
Workplan
Internal State
Plans
Purpose
A plan developed by EPA that
specifies goals, objectives,
subobjectives, targets, and resources
for all EPA programs, including the
waste management programs.
A plan developed by and EPA
region(s) in conjunction with EPA
headquarters that delineates the
priorities of greatest importance
across all media, including waste
management, for a particular fiscal
year.
A high-level plan developed by a
region(s) and state(s) that outlines the
agreement between the two
organizations for implementing media
and other critical programs, including
the waste management program.
A template developed by OSW for
distribution to EPA regions to capture
and identify specific projections and
issues related to the waste
management program for a particular
fiscal year.
The regional response to the BYP
Guidance indicating the regional
projections related to implementing
the waste management program for a
particular fiscal year.
Plan indicating state projections and
activities to be accomplished with
financial support during the
cooperative agreement period.
Varies
Frequency
Annual
Annual
Annual
Annual
Annual
Annual
Varies
Organization
Requiring
Plan or Input
Congress
EPA HQ, EPA
regions
EPA regions,
states
EPA OSW
EPA OSW
EPA OSW
State
Organization
Responsible for
Writing Plan
EPAHQ
EPA HQ, EPA
regions
EPA regions,
states
EPA OSW
EPA regions,
states
States
State
37
-------
Because many of the plans listed in Figure 12 have similar purposes and components, efforts may be
placed on revising a particular plan to meet the formatting requirements of another, while the substance
remains unchanged. For example, some EPA regions develop BYP submissions and then reformat
these submissions into organizational operating plans. Often, there is little recognized value associated
with developing these reformatted plans. The varied timing of the plans adds to the developers'
burden. Figure 13 depicts the complexity of the relationships, overlaps, and redundancies of these
plans. Although Figure 13 depicts hazardous waste management plans for states, EPA regions, and
EPA headquarters, not all organizations develop each type of plan (e.g., not all states have PPAs).
Finally, interviewees were not sure how some plans were used. For example, some plans are
developed and submitted to the requesting organization (internal or external) but are never reviewed or
tracked. Plans in subsequent years may or may not have a linkage to plans of the previous years. This
perceived lack of use resulted in the interviewees believing the plans had little or no value.
RECOMMENDATIONS
The Team identified three issues in this area. First, internal plans required by an organization may be
redundant. Second, plans required by regulation, statute, and/or other organizations may add to this
redundancy, increase burden, and take valuable time away from implementation activities. Third,
program staff at all levels are not convinced of the value of the various planning mechanisms and do not
see plans being used. The Team's recommendations addressing these issues follow.
The Team recommends that each organization (states, EPA regions, and EPA headquarters program
offices) streamline their own planning process for hazardous waste management. This could be
accomplished by reviewing the types, timing, purpose, components, contents, and uses of the plans
required internally. Where similarities exist between internal plans, each organization should consider
eliminating or combining the plans. Each organization should review external planning requirements to
see whether there is an opportunity to link internal needs and plans with external requirements.
38
-------
Figure 13. Relationship of National, Regional, and State
Hazardous Waste Management Plans
Agency
Multi Year
Plan
J Agency Strategic
Plan
Phase I/Phase III
Risk Analysis
Charts/Data Gaps
Headquarters
I
GPRA Annual
Performance Plan
RCRA
Implementation
Plan (RIP)
Beginning of Year
Plan (BYP)
Guidance
NECAP
Strategic Plan
I
Enforcement
MOA
Guidance
Legend
I Not included in
•PE PAA Scope
Included in PE
PAA Scope
Overarching
MOA
Regional
Strategic
Plan
Region
BYP
Submission of
Commitments
MOA
Submission of
Commitments
Operating
Plan
Region-State
Memorandum of
Performance
Partnership
Other State
Plans
State
Strategic
Plan
Agreement
Agreement
State
Multi Year
Permitting and
Corrective
Action Plan
T
Cooperative
Agreement
Workplan
J
Performance
Partnership
Grant Workplan
Operating Plan
+ T^
MOA
Submission of
Commitments
39
-------
The Team also recommends that each organization requiring another organization to submit a plan
review their planning requirements to determine whether the requirements could be streamlined. Again,
reviewing the types, timing, purpose, components, contents, and uses of the currently required plans
could result in the identification of similarities and provide opportunities for eliminating or combining
plans. Organizations also should consider alternative approaches to getting the same agreements,
information, or results. For example, two EPA regions participated in a pilot project to integrate EPA
headquarters and EPA regional priorities. During the project, the EPA regional and headquarters staff
met, discussed, drafted, and redrafted materials, resulting in lengthy, narrative Overarching Memoranda
of Agreements (OMOAs). After reviewing the process and results, EPA decided to conduct one high-
level meeting with no written requirement for OMOAs. Another possibility for achieving the desired
result is to use the tracking system discussed in Finding 2 of this chapter, especially if the plan is used to
identify a universe, set targets, and track progress in meeting those targets (e.g., BYP).
Relating to the hazardous waste management program, the Team specifically recommends reviewing the
needs and uses of OSW's BYP and OECA's MO A. EPA regions submitted their FY 1999 BYPs in
December 1998. EPA headquarters submitted the GPRA Annual Plan for FY 2000 in September
1998. Although the BYPs are multi-year, they are not useful in developing subsequent GPRA annual
plans, because the outyear projections are combined to cover more than one year. EPA regions are
unclear about the relationship between the BYP projections and the projections of the GPRA Annual
Plan. Similar concerns were raised with OECA's MO A. Although states do not develop these
documents, they do provide EPA regions with input and share the concerns.
Finally, where plans are not used, the Team recommends eliminating them. Where plans serve a useful
purpose, each organization should clearly state the purpose of the plan, identify where and how it is
being/will be used, and communicate that to program staff, especially the developers of the plan.
40
-------
CHAPTER 4
STABILITY ANALYSIS
The Team examined factors that may impact or require changes to either the data or processes within
the PE PAA scope, including pending legislation, Agency initiatives, system development efforts within
and outside EPA, new and/or evolving program requirements, and variances in workflows and data
needs across multiple stakeholders involved in the hazardous waste management program.
FA CTORS THA TIMPA CT ACROSS THE PE PROGRAM AREA
The stability of data and activities in the PE PAA will be influenced by how other PAA teams identify,
define, and model information related to the implementation of the hazardous waste management
program. All PAA efforts will investigate the processes and information needs within their individual
scope (e.g., UID will be concerned with data, activities, and system needs associated with identifying
hazardous waste handlers). Most of the data and processes within the PE PAA scope (i.e., related to
grants, plans, and evaluations) rely on information created by activities generated and included in other
PAAs. Because of this connection between PE PAA and implementation PAAs, a potential exists for
change to the data elements recommended by the Team (see Appendix A). The PE PAA Team
suggests that subsequent PAA teams consider how their recommended data elements affect those of
the PE PAA Team. Where data elements are needed for program implementation activities, future
PAA teams need to ensure, to the extent possible, that the new data elements also meet the needs of
program evaluation activities. Future PAA Teams who recommend revising the data elements in
Appendix A should work with the CC to ensure that the revised data elements continue to meet the
information needs identified by the PE PAA Team.
Because the responsibilities of the PE PAA Team conclude with the submission of this report, the
WIN/INFORMED ESC, the CC, and Project Coordinators (Coordinators) are responsible for (1)
ensuring that subsequent PAA teams consider the potential effects of their recommendations on PE
PAA recommendations and (2) coordinating with subsequent PAA teams to ensure user requirements
related to plans, grants, and evaluations are considered during future analyses. Additionally, while each
PAA team is responsible for tracking initiatives that may impact their program area, the CC and the
Coordinators are responsible for tracking the impact of the overarching initiatives across the entire
WIN/INFORMED effort. These initiatives include: Reinventing Environmental Information, Burden
Reduction, One Stop, Facility ID, and the
41
-------
renegotiation of core performance measures under NEPPS. Because of the evolving nature of
initiatives, it is difficult to predict definitively the future relationships between some of these existing
initiatives, as well as emerging ones, and WIN/INFORMED. However, by tracking these activities, and
in turn defining that relationship, WIN/INFORMED will be able to better clarify its data needs in ways
that will leverage the successes of other projects.
FACTORS THAT IMPACT THE PLANNING-EVALUATION CYCLE
The Office of the Chief Financial Officer (OCFO) is developing an Agency-wide accountability system
to track and report on performance and resource information as required by GPRA and Agency
managers. As of this writing, the system was not developed to determine with any degree of accuracy
what effects the accountability system requirements would have on the PE PAA recommendations.
The CC or the Coordinators will track the development of OCFO's accountability systems to ensure
that automated systems developed as a result of the Team's recommendations will be able to link with
EPA's new accountability system.
In developing performance measures to be used under GPRA, PPAs, and other initiatives, states, EPA
regions, and EPA headquarters are moving away from measuring activities and toward measuring
environmental results. The automated systems recommended to capture these measures need to be
designed with the flexibility to accommodate this change.
GPRA requirements and, subsequently, EPA interpretation and implementation of these requirements
are new and evolving. As such, the data and activities related to GPRA may change. To
accommodate potential changes in GPRA data requirements, the Team recommends a flexible
framework for the automated systems the Team is proposing. This flexibility will increase the likelihood
that future GPRA data requirements can be addressed without having to significantly modify an
automated system.
EPA evaluations of state programs are evolving. The NEPPS partnership between states and EPA
regions has led regions to move toward more targeted performance evaluations. The proposed
structure of the automated systems will accommodate a full range of performance and evaluation
procedures. The approach recommended here would allow for quantitative and qualitative tracking of
mutually agreed upon evaluation areas and measures.
FACTORS THAT IMPACT THE GRANT CYCLE
Applicants developing workplans for PPGs, as well as 3011 and 8001 Cooperative Agreements, use
many different processes. Depending on the applicant, the grant type, and the corresponding
workplan, commitments may include specific targets (e.g., numbers of activities) or may include only
narrative descriptions of activities to be performed. The Team attempted to identify and define data
42
-------
elements and related activities in a manner that would accommodate these differences, offering flexibility
to all stakeholders in meeting grant information needs. The automated system capturing the workplan
may not meet the specific needs of a state but remains general enough to meet the minimal needs of all
states. However, the proposed system should be designed to allow states to adapt the information
tracked in the system, so their needs can be met.
State development of PPGs is a new and evolving process, making the data and activities identified
inherently unstable. As the PPG process becomes better defined (i.e., established business rules and
clearly identifiable information needs), the data and activities should be revisited and revised as
necessary.
43
-------
This page left intentionally blank.
44
-------
CHAPTER 5
FUTURE DIRECTIONS
This chapter presents the roles of the Team, the Coordinators, the CC, the ESC, and the Design Team
upon completion of the PE PAA and PE Final Report. It also presents the Team's suggested high-level
approach for implementing recommendations that the ESC accepts.
ROLES
1. Team
The Team's efforts end when this report is presented to the ESC (scheduled for March 1999). It is
expected that a state, EPA regional, and EPA headquarters Team member will participate in the Design
Team formed to implement accepted system recommendations. It is likely that one or more Team
members may participate or lead efforts to implement accepted recommendations for process
improvement.
Currently, one state and one EPA regional member of the Team are members of the UID and Waste
Activity Monitoring (WAM) PAA Team (UID began in October 1998 and as of this writing WAM is
starting up). The Team believes this participation will be one of the necessary links to ensure the PE
PAA results and potential impacts are considered during the UID and WAM analyses.
2. Project Coordinators
The Coordinators are responsible for briefing subsequent PAA Teams on the PE PAA findings and
recommendations, particularly those supported by the ESC. In their briefings, the Coordinators will
include the specific data elements recommended for grants, plans, and evaluations. The Coordinators
also will track the potential impacts of outside activities on the PE recommendations, as discussed in
Chapter 4.
3. Coordinating Committee
The CC is responsible for providing overall coordination among and between the PAA Teams and
ensuring that other PAAs consider the needs of the PE area. The CC will make necessary changes to
the overall project plan, schedule, and resources to accommodate implementation of the accepted PE
recommendations.
45
-------
4. Executive Steering Committee
The ESC will evaluate the PE recommendations and decide which, if any, to implement. The ESC will
need to commit resources and provide continued leadership for promoting the accepted
recommendations. The ESC will identify the appropriate organizations to implement an accepted
recommendation.
5. Design Team
The ESC will task the Design Team with the accepted system recommendations. The Design Team is
responsible for implementing the system recommendations.
RECOMMENDED IMPLEMENTA TION APPROACH
1. Establish Implementation Team
The Team recommends that the ESC or CC establish an implementation team for each of the accepted
recommendations. Where the related recommendations could be combined into one effort, the ESC or
CC may want to task the team with implementing more than one recommendation. For example, all
three process improvement recommendations could be combined. The implementation team could be a
team specifically formed to address the recommendation(s) or could be an established team of experts.
The implementation team may include representatives from states, EPA regions, and EPA
headquarters.
2. Identify Champion
The Team recommends that the ESC identify a "champion" for the implementation of each accepted
recommendation. The champion's responsibilities would include (1) coaching the implementation team
as needed, (2) providing requested information, (3) ensuring team member participation (especially for
multi-organizational teams), (4) ensuring adequate resources, and (5) promoting the implementation of
the assigned recommendation(s). To accomplish these responsibilities, the Team believes that the
champion should be a member of the CC, an Associate Division Director, or a Division Director.
46
-------
SCHEDULE
As outlined in the WIN/INFORMED Project Plan, PE system design is not scheduled to begin until
winter 2002. The CC agreed that the remaining PAAs should be conducted before design begins on
PE recommended systems, because the PE area uses data captured by other programs. Resource
constraints also may affect this schedule.
Because PE system design is not scheduled to begin until winter 2002, the PE Team believes timely
implementation of accepted process improvement recommendations would demonstrate progress and
useful results. The Team suggests that implementation projects for process improvements be initiated
shortly after acceptance by the ESC and be designed to be completed within six to twelve months of
the start date. In the short-term, the Team believes the Design Team should investigate the Partnership
2000 system further to determine if it meets specified user needs.
47
-------
APPENDIX A.
RECOMMENDED DATA ELEMENT LIST
LEGEND
Name:
Definition:
Source:
Code:
History:
Owner:
The English title or phrase used to identify the data element.
An explanation of the meaning of the data element.
The origin information for the data element (e.g., current systems such as RCRIS, BRS). These data elements are recommended by the PE PAA Team and
should not be deleted by other WIN/INFORMED PAA efforts without consulting the CC. No data elements from RCRIS or BRS are being deleted as a result of
this analysis effort. As noted elsewhere in this report, ongoing efforts/initiatives may impact this list of data elements. In addition, the data elements listed
below may be revised through the RCRIS/BRS change management process.
Alpha-numeric system identifier for a data element.
The type of record that must be maintained for the data element.
Current history indicates that only the most recent occurrence of a particular data element be maintained by the information system.
Basic history indicates that a chronology or tracing of multiple occurrences of the same data element be maintained and retrievable by the information system.
Basic history allow users to retrieve and view or report on trends or changes for a specific data element.
The organization responsible for ensuring data quality of the data element. Implementing organization is the region or authorized state implementing the
program.
NOTE:
(1) This list of recommended data elements only includes the information the PE PAA Team believes is necessary to meet the planning and accomplishment
needs discussed in the main body of this report. Other related information such as "permittee name" or "facility identification number" falls outside the
scope of the PE PAA. Other PAA teams should consider the implications of this when conducting their analyses. Chapter 4 (Stablility Analysis) provides a
detailed discussion on future PAAs and the information needs they will address. State and EPA acceptance of the data elements listed in Appendix A
denotes agreement that these data elements are a starting point for the minimum requirements of the hazardous waste program and will be included in a
national information system, although they may be revised by subsequent PAAs.
(2) Data elements related to GPRA corrective action and permitting baselines are "flags" or "tagged" (e.g., a file of specific RCRIS facility ID numbers)
facilities that comprise the baseline. As GPRA data elements are still evolving, however, other WIN/INFORMED analysis efforts may revise the GPRA
related data elements listed here.
A-l
-------
PART A-l: RECOMMENDED DATA ELEMENTS CURRENTLY COLLECTED
IN RCRIS/BRS THAT ARE MANDATORY CORE/NATIONAL DATA*
* (MANDATORY CORE/NATIONAL DATA refers to data that must be entered into and tracked in the national RCRA data system(s) (RCRIS/BRS/RCRAInfo) by all
implementing Regions and States each and every time the activity occurs, and following the nationally agreed upon definitions to ensure consistency.)
Name
Definition
Source j Code
History
Owner
RCRIS DATA
CORRECTIVE ACTION EVENTS
GPRA corrective
action baseline
universe
RCRA Facility
Assessment (RFA)
Completed
Notice of
Contamination
Determination of
Need for RCRA
Facility Investigation
(RFI)
1 997 GPRA corrective action baseline universe. This universe captures a
specific set of facilities by ID number which were identified as high
priority corrective action candidates in the baseline year of 1 997. This is
a "snapshot" universe, frozen in time.
The date by which the RFA is completed.
Receipt by the Agency of written notification that contamination has been
discovered at the RCRA facility and that the RCRA facility has notified
all persons potentially impacted by the release of hazardous constituents.
This event indicates whether an RFI or further investigations is necessary
to analyze the extent of contamination at this facility. An RFI is usually
necessary when, after the initial assessment, there is evidence of, or the
likelihood of, a contamination release which poses a current or potential
threat to human health and/or the environment. The event can be
completed after the initial assessment.
Status Codes:
YE: RFI is necessary; should be entered when further investigation is
needed.
NO: RFI is not necessary; should be entered when further
investigation is not needed. "NO" indicates that an RFI will not
be needed at this site because remediation is not necessary.
i
RCRIS This universe of
specific facilities
is captured by a
file of ID #s
maintained by HQ.
RCRIS CA050
RCRIS CA060
RCRIS CA070
Current
Basic
Basic
Basic
PSPD
Implementing
organization
Implementing
organization
Implementing
organization
A-2
-------
Name
Corrective Action
(CA) Prioritization
RFI Imposition
RFI Workplan
Approved
RFI Report Approved
Referred to a Non-
RCRA Authority
Definition
This event indicates that a facility (or area) has been prioritized using the
National Corrective Action Prioritization System (NCAPS) or an
equivalent system which has been approved by EPA Headquarters. A
status code for the priority of the facility or area should be entered at the
same time as the prioritization complete date. High, Medium, and Low
determinations should be based on current national guidance.
Status Codes :
HI: Facility (or area) was assigned a high corrective action priority.
ME: Facility (or area) was assigned a medium corrective action priority.
LO: Facility (or area) was assigned a low corrective action priority.
The event by which the State or EPA formally imposes an obligation upon
the owner/operator of a facility regulated by RCRA, or the equivalent
state law, to conduct an RFI at its facility.
The event by which the State or EPA approves the RFI workplan
submitted by the RCRA facility.
The event by which the State or EPA accepts the findings and
recommendations of the RFI report submitted by the RCRA facility. No
entry should be made under this code until the RFI enables a formal
agency decision to continue with CMS or terminate the corrective action
process.
The facility (or area) has been referred to CERCLA or some other Federal
Non-RCRA authority. As a matter of program policy, once a facility is
referred to CERCLA or other non-RCRA Federal authority, progress of the
facility would not be actively tracked by RCRA and the facility would not
be expected to "return" to RCRA, barring some unforeseen event.
Status Codes :
SF: Corrective Action at the facility or area referred to CERCLA.
OT: Corrective Action referred to another non-RCRA Federal
Authority.
Source Code
RCRIS CA075
RCRIS CA100
RCRIS CA150
RCRIS CA200
RCRIS CA210
!
History
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A-3
-------
Name
Stabilization
Measures Evaluation
CMS Imposed
CMS Workplan
Approved
Definition
This event indicates that the feasibility and appropriateness of
stabilization activities at this facility have been evaluated. This
evaluation should be completed using the National Corrective Action
Stabilization Questionnaire or a similar type of evaluation which asks the
same range of questions. A status code should be entered for the areas
covered by each evaluation. The status codes are consistent with the
possible outcomes from the National Corrective Action Stabilization
Questionnaire.
Status Codes:
YE: This facility is amenable to stabilization activity based on the
status of corrective action work at the facility, technical factors,
the degree of risk, timing considerations and administrative
considerations.
NF: This facility is not amenable to stabilization activity at the
present time, because it appears to be technically infeasible or
inappropriate.
IN: This facility is not amenable to stabilization activity because of a
lack of technical data. An evaluation had been completed, but
further data is necessary to determine stabilization measures,
feasibility or appropriateness. This status should be changed
when data becomes available.
NR: This facility is not amenable to stabilization activity at the
present time for reasons other than: ( 1) it appears to be
technically feasible or inappropriate (NF); or (2) there is a lack of
technical information (IN). Reasons for this conclusion may be
the status of closure at the facility, the degree of risk, timing
considerations, the status of corrective action work at the facility,
or other administrative considerations.
The event by which the State or EPA formally imposes the obligation
upon a RCRA facility to perform a Corrective Measures Study (CMS).
The event by which the State or EPA formally approves the CMS plan
submitted by the RCRA facility. No entry should be made under this code
until the Agency intends for the RCRA facility to begin conducting the
CMS.
Source Code
RCRIS CA225
RCRIS CA250
RCRIS CA300
History
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
A-4
-------
Name
CMS Approved
Decision on Petition
for No Further Action
Date for Public Notice
on Proposed Remedy
Date for Remedy
Selection (CM
Imposed)
Corrective Measures
Design Approved
CMI Workplan
Approved
Determination of
Tech Impracticability
Certification of
Remedy Completion
(CM)
Definition
The event by which the State or EPA approves the final CMS report
submitted by the RCRA facility. No entry should be made under this code
until sufficient data, information, has been provided to the Agency so that
a decision to continue or terminate the corrective action process can be
made.
The event by which the State or EPA formally approves the petition by the
RCRA facility for no further action.
The event by which the State or EPA sends public notice that a proposed
remedy has been tentatively selected for a RCRA facility. The public
notice should specify where the documents upon which the Agency made
its decision are located and when they are available for public review.
The event by which the State or EPA formally notifies the RCRA facility
to initiate the corrective measure that has been proposed in the
notification process and is hereby incorporated into the RCRA facility's
permit or order.
The event by which the State or EPA formally notifies the RCRA facility
that the design of the corrective measure is acceptable.
The event by which the State or EPA approves the Corrective Measure
Implementation Program Plan, Construction Plans and Specification,
Design Reports, Cost Estimates, Project Schedule, Operation and
Maintenance Plan, Study Reports, Construction Quality Assurance
Program Plan/Documentation and the Corrective Measure Implementation
Report incorporating comments received on draft submissions.
The event by which the State or EPA formally notifies the RCRA facility
that the selected remedy cannot be accomplished because it is technically
impracticable.
The event by which the State or EPA formally notifies the RCRA facility
that it accepts its certification that the remedy specifications in the permit
or order have been met, and that the specified remedy or remedies has
been completed, and/or operation and maintenance requirements only
remain in order to maintain this level of performance.
Source Code
RCRIS CA350
RCRIS CA375
RCRIS CA380
RCRIS CA400
RCRIS CA450
RCRIS CA500
RCRIS CAS 10
RCRIS CA550
History
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A-5
-------
Name
Stabilization
Measures
Implemented
Stabilization
Construction
Completed
Definition
EPA's or the State's notification or written acknowledgment to the RCRA
facility that a stabilization activity or activities are required or otherwise
being undertaken. The notification mechanism could be an Enforcement
order, order modification, permit, or permit modification, or similar
enforceable state instrument requiring the facility to undertake
stabilization activity; it may also take the form of a written
acknowledgment from EPA or the State that stabilization activity is being
undertaken. The notification or acknowledgment must contain written
stabilization objectives, goals, performance standards, or desired results.
The stabilization activity must control or abate threats to human health
and/or the environment from releases, and/or prevent or minimize the
further spread of contamination.
The event by which the State or EPA formally notifies the RCRA facility
that the interim measures undertaken have been completed to the
satisfaction of the Agency; and/or the event by which the State or EPA
formally notifies the RCRA facility that stabilization objectives have
been met, but require continued operation and maintenance to maintain
this level of performance. Multiple occurrences of this event may be
entered and tracked in an information system.
Source Code
RCRIS CA600
RCRIS CA650
History
Basic
Basic
Owner
Implementing
organization
Implementing
organization
A-6
-------
Name
Definition
Source
Code
History
Owner
Human Exposures
Controlled
Determination
(GPRA)*
*(FY99: Changing to
CURRENTHUMAN
EXPOSURES UNDER
CONTROL)
This event indicates there are no current unacceptable risks to humans due
to releases of contaminants at or from the facility that are subject to RCRA
Corrective Action. This facility wide measure is based on current
conditions at the facility, and covers all types of releases and media.
Human exposure controls or other corrective action must have been
implemented in every case where a release has posed a current
unacceptable risk to human health before this event can be entered.
(Environmental indicators are not a measure of activity at the facility, but
a measure of the environmental status of the facility) The event may be
counted when one or more of the following are met:
1. Remedial measures have been implemented with the result that
all maximum contaminant concentrations detected or reasonably
suspected are less than or equal to their respective action levels
(e.g., MCLs for groundwater, a 10-6 risk level for other
contaminants, or any other number designated as the action
level) or do not exceed an Agency specified cleanup standard for
the facility.
OR
2. There is no unacceptable human exposure to any contaminant
concentration above action levels that has been detected or is
reasonably suspected based on current contaminant
concentrations and current site conditions. Although
contamination remains at the facility that may require further
Remediation, action has been taken or site conditions are
otherwise such that unacceptable threats to human health from
actual exposure to the contamination are not plausible based on
current uses of the sites. Such actions may include the use of
physical barriers or institutional controls (e.g., deed restrictions
or alternative water supply).
Status Codes:
YE: Yes, applicable as of this date.
NA: Previous determination no longer applicable as of this date.
NC: No control measures necessary.
NO: Facility does not meet definition.
IN: More information needed.
NOTE: During FY99, this event code is undergoing revision both in
definition and in allowable status codes. Refer to RCRIS DED.
RCRIS
CA725
Basic
Implementing
organization
A-7
-------
Name
Definition
Source
Code
History
Owner
Release to GW
Controlled
Determination
(GPRA)*
*(FY99: Changing to
MIGRATION OF
CONTAMINATED
GROUNDWATER
UNDER CONTROL)
This event indicates that groundwater releases subject to RCRA
Corrective Action at the facility are controlled. This event may be
counted when one or more of the following conditions are fulfilled and
documented by field measurements and/or observations including the
direction of groundwater flow gradients over time.
For all known or reasonably suspected groundwater contamination at the
facility in excess of action levels, or in excess of an Agency specified
clean-up level:
1. An engineered system has been installed that is designed and
operating (including performance monitoring) to effectively
control the further migration beyond a designated boundary such
as the engineered system, the facility boundary, a line up
gradient of receptors, or the leading edge of the plume as defined
by levels above the Agency established action levels or clean-up
standards.
OR
2. The Agency has determined that the groundwater clean-up
objectives can be met without the use of an engineered system
through the remedial measures selected, including facilities
where the contamination will naturally attenuate.
Status Codes:
YE: Yes, applicable as of this date.
NA: Previous determination no longer applicable as of this date.
NR: No release to groundwater.
NO: Facility does not meet definition.
IN: More information needed.
NOTE: During FY99, this event code is undergoing revision both in
definition and in allowable status codes. Refer to DED.
RCRIS
CA750
Basic
Implementing
organization
A-8
-------
Name
Definition
Source
Code
History
Owner
CA Process is
Terminated
This event indicates the completion of the corrective action process; that
active remedial measures, as specified in the RCRA permit or enforcement
order, are completed for the entire facility or for areas at the facility. This
event should be entered 1) after the Certification of Remedy Completion
or Construction Completion (CMI Completed) (CA 550), and/or 2) after a
stabilization measure(s) has been completed in a manner that meets the
stabilization objectives, goals, performance standards, and/or desired
results (CA650), and terminating corrective action at this point at the
facility or area would satisfy all permit or order requirements for CA.
Status Codes:
NF: No Further Action.
RM: Remedial Activities Completed.
RCRIS
CA999
Basic
Implementing
organization
CLOSURE EVENTS
Plan Received -
Closure
Date closure plan is received by region or state.
RCRIS
CL310
Basic
Implementing
organization
Plan Approved •
Closure
Date, following required public notice, that final approval is granted by
region or state.
Status Codes:
ME: Final Closure (all units at facility are closing).
MO: Partial Closure (only one or some of the units at the facility are
closing; others remain in operation).
RCRIS
CL360
Basic
Implementing
organization
Receive Closure
Certification
Date owner/operator and independent registered engineers' certification is
received by region or state verifying that the approved closure plan was
implemented as specified.
Status Codes:
NO: Not according to plan
YE: According to plan
RCRIS
CL370
Basic
Implementing
organization
Closure Verification
Date region or state approves/accepts or rejects the closure certification
and notifies the facility in writing,,also releasing facility from financial
responsibility requirements to maintain closure cost assurances.
Status Codes:
CA: Clean closure, acceptable.
CU: Clean closure, unacceptable.
DA: Closure with waste in place, acceptable.
DU: Closure with waste in place, unacceptable.
RCRIS
CL380
Basic
Implementing
organization
A-9
-------
Name
GPRA hazardous
waste controls /
permits baseline
universe
Part A Submitted
Part A Determination
Process Determination
Part B Call-In
Pre-Compliance
Certification
Submitted
Pre-Compliance
Certification Review
Completed
Notification of
Compliance Testing
Definition
INTERIM STATUS, BIF and OPERATING PERMIT EVENTS
1 997 GPRA hazardous waste facility baseline universe. This universe
captures a specific set of facilities by ID number which were identified as
being in the Permitting Workload universe (i.e., needing a permit) in the
baseline year of 1 997. This is a "snapshot" universe, frozen in time.
Date Part A form received by EPA region or authorized state.
Status Codes
IS: Initial Submittal
CS: Request for Change under Interim Status
PB : Submitted with a Part B or Mod Request
Date of EPA regional or state authorized action, such as date of letter to
facility acknowledging receipt of Part A application.
Status Codes:
AK: Acknowledgment of Part A Receipt
VE: Verified by Inspection to Exist
AP: Approval of Interim Status Change
DR: Denied Request
1C: Part A Late, Interim Status Compliance Letter Issued
Date of inspection (field verification) of existence of hazardous waste
management unit(s), or date of facility's document certifying the unit's
status.
Status Codes:
AD: Agency (State or EPA) Determination
FD: Facility Certified Document
Date of letter from EPA region or authorized state requiring submission of
permit application by a certain date.
The date that the pre-compliance certification regarding compliance with
boiler/industrial furnace (BIF) regulations is received by the state or EPA.
The date that the state or EPA completes the review of the BIF pre-
compliance certification, and makes a determination as to whether it is
acceptable or not.
The date that the facility notifies EPA or the state of the date on which
they will perform testing to demonstrate compliance with the BIF
regulations.
Source Code
RCRIS This universe of
specific facilities
is captured by a
file of ID #s
maintained by HQ.
RCRIS OP001
RCRIS OP002
RCRIS OP003
RCRIS OP010
RCRIS OP011
RCRIS OP012
RCRIS OP013
!
History
Current
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Owner
PSPD
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 10
-------
Name
Case -By-Case
Compliance
Extension Requested
Loss of Interim Status
(LOIS)
Case -By-Case
Extension Granted
Part B Received
Notification of
Automatic Extension
Compliance
Certification
Submitted
Compliance
Certification Review
Completed
Definition
The date on which EPA or the state receives a request from the facility for
an extension to the date by which they must be in compliance with the
BIF regulations.
The date on which the facility loses interim status.
Status Codes : (Reason for Loss of Interim Status)
01 : Failed to submit Part B and to certify compliance with
groundwater monitoring and financial responsibility
requirements
02: Failed to submit Part B and to certify compliance with financial
responsibility requirements
03: Failed to submit Part B and to certify compliance with
groundwater monitoring requirements
04: Failed to certify compliance with groundwater monitoring and
financial responsibilities
05: Failed to submit Part B
06: Failed to certify compliance with groundwater monitoring
requirements
07: Failed to certify compliance with financial responsibility
requirements
08: Interim status lost, reason not yet determined, or other than above
Date on which EPA region or authorized state grants an extension for
compliance with the BIF regulations.
Status Codes :
AR: Approved request
DR: Denied request
Date EPA region or authorized state received the Part B application.
Status Codes:
CR: Confidentiality Requested
CS: Confidentiality Substantiated
CU: Confidentiality Unsubstantiated
Date on which extension is automatically granted for compliance with BIF
regulations.
The date on which the EPA or authorized state receives the certification
from the facility that they are in compliance with the BIF requirements.
The date on which the EPA or authorized state completes its review of the
BIF compliance certification submitted by the facility and determines
whether or not it is acceptable.
Source Code
RCRIS OP014
RCRIS OP015
RCRIS OP016
RCRIS OP020
RCRIS OP021
RCRIS OP022
RCRIS OP023
History
Basic
Current
Basic
Basic
Current
Current
Current
Owner
Implementing
organization
Implementing
organization
Implementing
organzization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 11
-------
Name
Compliance
Extension Expires
Trial Burn Conducted
Public Notice
Final Determination
(GPRA) (Operating
Permit)
GPRA hazardous
waste controls / post-
closure permits
baseline universe
Post-Closure Part B
Call-In
Post-Closure Part B
Received
Definition
The date on which the BIF compliance extension granted by EPA or the
authorized state expires.
The date on which the trial burn (field test) of the combustion/incinerator
unit is conducted.
First day of 45 day Public Comment Period; date on which newspaper and
radio announcements occur.
Status Codes:
DP : Draft Permit Issued
ID: Intent to Deny
Date EPA region or authorized state issues, or denies operating permit;
corresponds to date on signed permit or letter to facility denying permit.
Status Codes :
PD: Permit denied.
PG: RCRA permit issued with HSWA requirements, corrective action
schedule not necessary.
PI: RCRA permit issued, HSWA requirements do not apply to this
facility.
PJ: RCRA permit issued, with HSWA requirements, including a
schedule for corrective action.
PP: Permit issued by state, HSWA requirements apply but EPA permit
covering HSWA has not been issued.
POST-CLOSURE EVENTS
1 997 GPRA hazardous waste facility baseline universe. This universe
captures a specific set of facilities by ID number which were identified as
being in the Post-Closure Permitting Workload universe (i.e., needing a
post-closure permit) in the baseline year of 1 997. This is a "snapshot"
universe, frozen in time.
Date of letter from EPA region or authorized state requiring submission of
permit application by a certain date.
Date EPA region or authorized state received the Part B application.
Status Codes :
CR: Confidentiality Requested
CS: Confidentiality Substantiated
CU: Confidentiality Unsubstantiated
Source Code
RCRIS OP024
RCRIS OP080
RCRIS OP160
RCRIS OP200
RCRIS This universe of
specific facilities
is captured by a
file of ID #s
maintained by HQ.
RCRIS PC010
RCRIS PC020
History
Current
Basic
Basic
Basic
Current
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
PSPD
Implementing
organization
Implementing
organization
A- 12
-------
Name
Public Notice
Final Determination
(GPRA) (Post Closure
Permit)
Plan Received -
Closure/Post-Closure
Plan Approved -
Closure/Post-Closure
Receive Closure
Verification
Definition
First day of 45 day Public Comment Period; date on which newspaper and
radio announcements occur.
Status Codes:
DP : Draft Permit Issued
ID: Intent to Deny
Date EPA region or authorized state issues, or denies post closure permit;
corresponds to date on signed permit or letter to facility denying permit.
Status Codes:
PD: Permit denied.
PG: RCRA permit issued with HSWA requirements, corrective action
schedule of compliance not necessary.
PI: RCRA permit issued, HSWA requirements do not apply to this
facility.
PJ: RCRA permit issued, with HSWA requirements, including a
schedule of compliance for corrective action.
PP: Permit issued by state, HSWA requirements apply but EPA permit
covering HSWA has not been issued.
Date closure/post-closure plan is received by region or state.
Status Codes :
CL: Closure
PC: Post-Closure
Date, following required public notice, that final approval is granted by
region or state.
Status Codes :
ME: Final Closure
MF: Final Post-Closure
MO: Partial Closure
MP: Partial Post-Closure
Date owner/operator verification is received by region or state verifying
that the approved closure plan was implemented as specified.
Status Codes:
NO : Not According to Plan
PC: Post-Closure
YE: According to Plan
Source Code
RCRIS PC160
RCRIS PC200
RCRIS PCS 10
RCRIS PC360
RCRIS PC370
History
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 13
-------
Name
Closure Verification
Definition
Date region or state approves/accepts or rejects the closure certification
and notifies the facility in writing.
Status Codes:
AC: Acceptable Closure
UC: Unacceptable Closure
Source Code
RCRIS PC380
History
Basic
Owner
Implementing
organization
COMPLIANCE/ENFORCEMENT EVENTS
Verbal Informal
Enforcement Action
Written Informal
Enforcement Action
Combination-
Informal Enforcement
Action
Initial § 3008 (a)
Compliance order
Initial Imminent
Hazard Order
Initial Monitoring
and Testing Order
Initial § 3008 (h)
Interim Status
Corrective Action
Orders
Notice of Non-
Compliance
Combination-Initial
Formal Enforcement
Action
The event by which the state or EPA issues a verbal informal enforcement
action. Examples: date of site visit/conversation or telephone call.
The event by which the state or EPA issues a written informal enforcement
action. Examples: Letter of Warning (LOW) or Notice of Violation
(NOV).
The event by which the state or EPA issues a combination informal
enforcement action. (Combination of CE1 10 and CE120.)
The event by which the state or EPA issues an initial § 3008(a), or
equivalent state authority, enforcement action.
The event by which the state or EPA issues an initial imminent hazard
enforcement action under § 7003 or equivalent state authority.
The event by which the state or EPA issues an initial monitoring and
analysis enforcement action under § 3013 or equivalent state authority.
The event by which the state or EPA issues an initial § 3008(h), or
equivalent state authority, enforcement action. (NOTE: This event is also
tracked in the corrective action instrument file in the corrective action
module ofRCRIS. It does not have to be entered in both places.
Currently, if it is entered in the Corrective Action Module, that is
sufficient. So while the event itself must be tracked at the national level,
it is not mandatory that it be tracked in the CM&E Module ofRCRIS.)
The event by which the state or EPA issues a notice of non-compliance to
a Federal facility.
The event by which the state or EPA issues a combination initial formal
enforcement action. (Combination of CE210, CE220, CE230 and/or
CE240.)
RCRIS CE110
RCRIS CE120
RCRIS CE190
RCRIS CE210
RCRIS CE220
RCRIS CE230
RCRIS CE240
RCRIS CE250
RCRIS CE290
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 14
-------
Name
Final § 3008 (a)
Compliance Order
Final Imminent
Hazard Order
Final Monitoring and
Testing Order
Final § 3008 (h)
Interim Status
Corrective Action
Orders
Federal Facility
Compliance
Agreement
CERCLA 106 Order
CERCLA 104 Order
Combination-Final
Formal Enforcement
Action
Referral to AG
Referral to DOJ
Referral to DA/CA
Combination-Judicial
Referral
Civil Action for
Compliance
Civil Action for
Imminent Hazards
Definition
The event by which the state or EPA issues a final § 3008(a), or equivalent
state authority, enforcement action.
The event by which the state or EPA issues a final imminent hazard
enforcement action under § 7003 or equivalent state authority.
The event by which the state or EPA issues a final monitoring and analysis
test enforcement action under § 3013 or equivalent state authority.
The event by which the state or EPA issues a final § 3008(h), or equivalent
state authority, enforcement action.
The event by which the state or EPA issues a final federal facility
compliance agreement.
The event by which the state or EPA issues a RCRA CERCLA 106
enforcement action.
The event by which the state or EPA issues a RCRA CERCLA 104
enforcement action.
The event by which the state or EPA issues a combination final formal
action. (Combination of CE310, CE320, CE330, CE340, CE360 and/or
CE370.)
The event by which the state or EPA issues a referral to the Attorney
General.
The event by which the state or EPA issues a referral to Department Of
Justice.
The event by which the state issues a referral to the District Attorney or
County Attorney.
The event by which the state or EPA issues a combination judicial referral.
(Combination of CE410, CE420 and/or CE430.)
The event by which the state or EPA issues an initial judicial civil action
for compliance.
The event by which the state or EPA issues an initial judicial civil action
for imminent hazard.
Source Code
RCRIS CE310
RCRIS CE320
RCRIS CE330
RCRIS CE340
RCRIS CE350
RCRIS CE360
RCRIS CE370
RCRIS CE390
RCRIS CE410
RCRIS CE420
RCRIS CE430
RCRIS CE490
RCRIS CE510
RCRIS CE520
History
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 15
-------
Name
Civil Action for
Compliance with
Previously Issued
Action
Civil Action for
Interim Corrective
Action
Civil Action for
Monetary Penalties
Combination-Civil
Actions
Consent Decrees
Judicial Orders
Criminal Actions
State to EPA
EPA to State
EPARCRAtoEPA
CERCLA
Federal Facility
Referral to EPA HQ
Combination- Admin.
Referral
Date of Enforcement
Action
Definition
The event by which the state or EPA issues an initial judicial civil action
for compliance of a previously issued action.
The event by which the state or EPA issues an initial judicial civil action
for interim corrective action.
The event by which the state or EPA issues an initial judicial civil action
for monetary penalties.
The event by which the state or EPA issues a combination initial judicial
civil action. (Combination of CE510, CE520, CE530, CE540 and/or
CE550).
The event by which the state or EPA issues a consent decree.
The event by which the state or EPA issues a judicial decree.
The event by which the state or EPA issues a criminal action.
The event by which the state refers a case to the EPA.
The event by which the EPA refers a case to the state.
The event by which the EPA refers a RCRA case to EPA CERCLA for
action.
The event by which the state or EPA refers a Federal Facility case to EPA
HQ.
The event by which the state or EPA issue a combination administrative
referral. (Combination of CE810, CE820, CE830 and/or CE850.)
The date the enforcement action was issued. For all formal actions
involving written documents, the date should be the same as the date the
document is signed. For an informal action, the date should reflect the
date the handler received the actual notification.
Source Code
RCRIS CE530
RCRIS CE540
RCRIS CE550
RCRIS CE590
RCRIS CE610
RCRIS CE620
RCRIS CE710
RCRIS CE810
RCRIS CE820
RCRIS CE830
RCRIS CE850
RCRIS CE890
RCRIS CEE_ACT_DTE
History
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 16
-------
Name
Definition
Source
Code
History
Owner
Date of Evaluation
The evaluation date is the first day of the inspection or record review
regardless of the duration of the inspection.
RCRIS
CE DATE
Basic
Implementing
organization
Corrective Action
Oversight (CAO)
Inspection
An on-site inspection of corrective action activities. When corrective
action on-site inspection is conducted as part of another inspection type
(CEI, CME, etc.), a separate Handler Evaluation form should be submitted
reporting the CAO component.
RCRIS
CMCAO
Basic
Implementing
organization
Case Development
Inspection (CDI)
A CDI may involve sampling to confirm the chemical
composition/characteristics of wastes handled by generators and
transporters, and their waste handling practices. In addition, facility
operations and design information may be reviewed, and manifests from
generators and transporters verified. A focused CDI may be conducted
when a CEI reveals possible RCRA violations, and could serve to gather
the additional data needed to support an enforcement case.
RCRIS
CMCDI
Basic
Implementing
organization
Compliance
Evaluation Inspection
(CEI)
An on-site evaluation of the compliance status of the handler with regard
to all applicable RCRA Regulations and Permits. Although portions of a
CEI evaluation may routinely be conducted in an agency office setting,
such "office" evaluations are considered as integral parts of the CEI in
terms of the evaluation completion date. The major function of the CEI is
overall review of the Handler's performance. The inspection includes an
on-site examination of records and other documents maintained by the
handler and an evaluation of the handler's compliance with all applicable
requirements and sampling (if applicable). Where appropriate, it includes
groundwater monitoring assessment outlines or plans, closure/post-closure
plans, contingency plan reviews, waste analysis plan reviews, and
preparedness and prevention plan reviews. Specifically excluded from the
CEI type of evaluation are Financial Record Reviews. This review is most
often conducted by "agency experts", and appropriately coded as
Financial Record Review (FRR) type of evaluation. (NOTE: OECA
prescribes that all operating treatment, storage, and disposal facilities
receive this type of inspection at least biannually.)
RCRIS
CMCEI
Basic
Implementing
organization
A- 17
-------
Name
Definition
Source
Code
History
Owner
Comprehensive (GW)
Monitoring
Evaluation (CME)
A detailed evaluation of the adequacy of the design and operation of a
facility's groundwater monitoring system as per EPA's Final RCRA
Comprehensive Groundwater Monitoring Evaluation Guidance
Document. Evaluation of the groundwater monitoring system design
should be conducted by a hydro geologist and includes the review of the
owner/operator's (o/o's) characterization of the hydro geology beneath
hazardous waste management units, monitoring well placement and
depth/spacing, and well design and construction. It is essential that the
CME ensure that the o/o has designed an adequate groundwater
monitoring system. In addition, an integral part of the CME is the review
of the operation of the groundwater monitoring system through an
evaluation of the o/o's sampling and analysis plan and its implementation.
CMEs should be scheduled, to the maximum extent possible, to coincide
with o/o sampling events to permit the field evaluation of sampling
techniques. Inspectors should collect splits or conduct EPA/State
sampling as a random check of groundwater quality data at any wells
which may have indicated releases to support enforcement of corrective
action. A comparison of EPA/State and o/o analytical results can be used
to assess laboratory accuracy and establish the reliability of o/o submitted
data. A CME should encompass everything covered in the CEI for
groundwater monitoring facilities. In addition CMEs should include:
a) a detailed investigation of the engineering features and
effectiveness of the groundwater monitoring system;
b) a detailed review of the facility's groundwater sampling and
analysis plan;
c) re-calculation of statistics at detection monitoring facilities to
ensure that the facility should not be in assessment;
d) detailed examination of the facility's assessment monitoring plan
and field implementation;
e) re-evaluation of groundwater flow direction; and
f) a substantial amount of sampling.
RCRIS
CMCME
Basic
Implementing
organization
Compliance Schedule
Evaluation (CSE)
An on-site inspection or other re-evaluation conducted to verify
compliance with enforcement actions resulting from a previous
evaluation, or to review deficiencies noted in previous inspection. It may
be a re-review of the adequacy of documents such as closure plans or
financial instruments previously found to be absent or deficient for which
no enforcement action has been taken. A Compliance Schedule
Evaluation should only be used if the effort involved, or the extent of
areas inspected, are insufficient to qualify as one of the more
comprehensive evaluation types listed above.
RCRIS
CMCSE
Basic
Implementing
organization
A- 18
-------
Name
Financial Record
Review (FRR)
RCRA CEI Performed
with Screening
Checklist
Comprehensive &
Coordinated
Inspection with CEI
Detailed Multimedia
Inspection with CEI
Multimedia Screening
Checklist Only
Non-Financial Record
Review (NRR)
Operation and
Maintenance
Inspection (OAM)
Definition
An extensive detailed review of a handler's compliance with financial
responsibility requirements. Financial Record Reviews are conducted in
the Agency office and not on- site.
RCRA CEI inspection performed with screening checklist.
This value includes the performance of a RCRA CEI in a coordinated
effort with other programs at a handler's site.
This value includes the performance of a RCRA CEI by a specially trained
inspector at a handler's site.
A CEI was not performed; however, the screening checklist was performed
alone or as part of another type of inspection.
An evaluation conducted in the Agency office involving a detailed review
of non-financial records.
The Operation and Maintenance Inspection is a periodic inspection of
how well a groundwater monitoring system continues to function once it
is considered well designed. The inspection focuses on the condition of
wells and sampling devices. Evaluation of well recovery notes, turbidity
of water, total depth, depth to water, etc. should be made and compared to
historic data. Sampling devices should be tested and if necessary pulled
and visually inspected. The findings of an operation and maintenance
inspection will indicate whether case development is warranted and/or
will serve to focus future CMEs. The inspector should be experienced in
evaluation of groundwater monitoring systems, e.g., hydro geologist. This
inspection can include sampling. However, if a great deal of sampling is
conducted, a separate sampling inspection should be recorded.
Source Code
RCRIS CMFRR
RCRIS CMMMB
RCRIS CMMMC
RCRIS CMMMD
RCRIS CMMMS
RCRIS CMNRR
RCRIS CMOAM
History
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A- 19
-------
Name
Other Evaluation
(OTH)
Determined Not to Be
a Significant Non-
Complier (SNN)
Definition
Any type of evaluation other than those listed above.
NOTE: OECA has proposed eliminating OTH and replacing it with 1 0
new evaluation types:
1) Used Oil Inspection (UOI),
2) Non-Subtitle C Inspection (SDI) - this would be for RCRA
inspections at Non-Subtitle C facilities suspected of
handling Subtitle C waste,
3) Off-Site Inspection (OSI)
4) Hazardous Spill Inspection (HSI)
5) Tribal Land Inspection (TLI)
6) Facility Status Inspection (FSI)
7) Subpart CC Inspection (SCI)
8) Subpart BB Inspection (SBI)
9) Subpart AA Inspection (SAI)
10) Small Business Policy Inspection (SBP)
This proposal will be described in detail in the Quarterly Report
distributed in March/April 1999 per the prevailing RCRIS Change
Management Process.
A determination has been made to remove the SNC designation for a
facility. This can be as a result of the facility returning to full physical
compliance with regulatory and/or statutory requirements or with a
compliance schedule. This evaluation is only applicable for former SNCs.
Source Code
RCRIS CMOTH
RCRIS CMSNN
History
Basic
Basic
Owner
Implementing
organization
Implementing
organization
A-20
-------
Name
Definition
Source
Code
History
Owner
Determined to Be a
Significant Non-
Complier (SNC)
A determination has been made to classify a facility as a SNC using the
following guidelines as set forth in the March 15,1996 Hazardous Waste
Civil Enforcement Response Policy (ERP). A SNC is a facility which has
caused actual exposure or a substantial likelihood of exposure to
hazardous waste or hazardous waste constituents; is a chronic or
recalcitrant violator; or deviates substantially from the terms of a permit,
order, agreement or from RCRA statutory or regulatory requirements. The
actual or substantial likelihood of exposure should be evaluated using
facility specific environmental and exposure information whenever
possible. This may include evaluating potential exposure pathways and
the mobility and toxicity of the hazardous waste being managed.
However, it should be noted that environmental impact alone is sufficient
to cause a facility to be a SNC, particularly when the environmental media
affected require special protection (e.g., wetlands or sources of
underground drinking water). Facilities should be evaluated on a multi-
media basis; however, a facility may be found to be a chronic or
recalcitrant violator based solely on prior RCRA violations and behavior.
[NOTE: This evaluatoin should occur and be entered into RCRIS no more
than ninety (90) days following the date of the evaluation/discovery of
violation.]
RCRIS
CMSNY
Basic
Implementing
organization
Sampling Inspection
(SPL)
This is an evaluation type in which samples (e.g., soil, sediment, surface
water, groundwater, waste) are collected for laboratory analysis. Sampling
inspections may be necessary for additional enforcement case
development or may be performed as part of oversight of closure, post-
closure, and/or corrective action activities being performed by the facility
owner/operator.
RCRIS
CMSPL
Basic
Implementing
organization
Compliance
Assistance Activity
(CAV)
The event by which any information or technical assistance is provided to
the regulated community to help it meet the requirements of
environmental law. This can be the date of an on-site visit conducted for
this purpose, or it can be the date of a telephone conversation, or the date
training is provided, or the date written outreach materials are mailed to
the facility. {NOTE: Refer to the OECA Operating Principles for further
guidance on the definition of compliance assistance.]
RCRIS
CMCAV
Current
Implementing
organization
Facility Self
Disclosure (FSD)
Assists in tracking and verifying that a Handler has self-disclosed the
existence of a violation and/or performed an audit and has submitted the
information as appropriate to the State or EPA.
RCRIS
CMFSD
Current
Implementing
organization
Area of Violation
Indicates the specific area of the RCRA regulations that are in violation.
RCRIS
CEV AREA
Basic
Implementing
organization
A-21
-------
Name
Definition
Source
Code
History
Owner
Date Violation
Determined
Date that a determination is made that the violation exists. This is not
necessarily the same date as the date of the inspection or evaluation (for
example, when the agency receives sample results or a legal
determination).
RCRIS
CEV DTEDET
Basic
Implementing
organization
Actual Resolved Date
The date the agency determines that the handler demonstrated physical
compliance (the date compliance was verified). The handler will be
considered to be out-of-full-physical-compliance until the actual resolved
date has been determined. Actual resolved date does not necessarily mean
that all enforcement actions are completed for this violation. For
violations of omission (such as not manifesting a load of waste) the actual
resolved date is the date of a written commitment by the handler to
comply in the future or the day of conviction in a criminal action. Penalty
payment is not a condition of physical compliance; however if non-
payment is the only violation then the actual resolved date is the date that
payment is received.
RCRIS
CEV ACT DTE
Basic
Implementing
organization
Scheduled Response
Date
Date by which the handler is to submit to the agency its documentation
that the violation has been brought into compliance. Scheduled response
dates are specified in enforcement actions as the compliance schedule. If a
number of activities are to be performed according to a compliance
schedule with more than one date, enter the date of the last action to be
taken by the handler to return to compliance. If Class of Violation is "P",
Scheduled Response Date is the date a decision is expected on the final
status of the pending violation (i.e.: the date on which it will be known
whether or not the pending violation is, or is not, a violation).
RCRIS
CEV SCH DTE
Basic
Implementing
organization
A-22
-------
Name
SEP/Enforcement
Milestone Code
Definition
ECA Environmental Compliance Audits. These audits are an
independent evaluation of a defendant/respondent's compliance
status with environmental requirements.
ECP Environmental Compliance Promotion. A project that involves
the dissemination of information, or the providing of training or
technical support, to a regulated party or to some or all members
of the defendant/respondent's economic sector to: 1) achieve and
maintain compliance with regulatory requirements; 2) determine
what are its regulatory requirements and thereby avoid
committing a violation; or 3) go beyond compliance by reducing
the generation, release, or disposal of pollutants beyond legal
requirements.
EMA Environmental Management Systems Audits. These audits are an
independent evaluation of a party's environmental policies,
practices, and controls.
EPP Emergency Planning and Preparedness. An emergency planning
and preparedness project is one where a defendant/respondent
provides assistance, such as computers and software,
telephone/radio communications systems, chemical emission
detection and inactivation equipment, HAZMAT equipment, or
training for first responders to chemical emergencies, to a
responsible state or local planning entity.
ERE Environmental Restoration. A project that goes beyond repairing
the damage caused by the violations to enhance the condition of
the environment adversely affected.
PHE Public Health. A project that provides diagnostic, preventive,
and/or remedial components of human health care that is related
to the actual or potential damage to human health caused by the
violation.
PPA Pollution Prevention Assessments are systematic, internal reviews
of specific processes and operations designed to identify and
provide information about opportunities to reduce the use,
production, and generation of toxic and hazardous materials and
other wastes.
Source Code
RCRIS CEE_S_MI_CDE
History
Basic
Owner
Implementing
organization
A-23
-------
Name
SEP/Enforcement
Milestone Code
(continued)
Definition
PPE Pollution Prevention. A project that reduces the generation of
pollution through 'source reduction', i.e., any practice that
reduces the amount of any hazardous substance, pollutant, or
contaminant entering any waste stream or otherwise being
released into the environment prior to recycling, treatment, or
disposal. If the pollutant or waste stream has been generated,
pollution prevention is no longer possible and the waste must be
handled by appropriate recycling, treatment, or disposal methods.
Pollution prevention can be accomplished by: 1)
Equipment/technology modifications; 2) Process or procedure
modifications; 3) Product reformulation/redesign; 4) Raw
materials substitution; 5) Improved
housekeeping/O&M/training/ inventory control; 6) In-process
recycling; 7) Energy efficiency/ conservation; 8) Other.
PRE Pollution Reduction. A project that results in a decrease in the
amount or toxicity of any hazardous substance, pollutant, or
contaminant entering any waste stream or otherwise being
released into the environment by a means that does not qualify as
'pollution prevention'.
SAA Site Assessments. These assessments are investigations of the
condition of the environment at a site, or of the environment
impacted by a site, and/or investigations of threats to human
health or the environment relating to a site.
Source Code
History
Owner
A-24
-------
Name
Definition
Source
Code
History
Owner
Type of Penalty
Amount Indicator
Code which indicates the type of penalty associated with the penalty
amount.
For 100 Series Enforcement Action Types:
No penalties should be associated with this type of enforcement
action series.
For 200 Series Enforcement Action Types:
PA Proposed Monetary Penalty. The amount of the total penalty in
dollars proposed in an initial enforcement action.
FA Final Monetary Penalty. The amount of the total penalty in
dollars a handler named in an enforcement action must pay
directly to the responsible agency.
For 300 Series Action Types:
FA Final Monetary Penalty. The amount of the total penalty in
dollars a handler named in an enforcement action must pay
directly to the responsible agency (for consent agreements with
SEP, this is exclusive of SEP credits).
FC Final SEP Cost. The final amount cited in an enforcement action
as the cost in dollars to the handler of a supplement
environmental project.
CR Final SEP Credit. The credit in dollars allowed by the agency
for the completed SEP and applied towards the total final
settlement amount.
For 400 Series Enforcement Action Types:
PA Proposed Monetary Penalty. The amount of the total penalty in
dollars credits, proposed in an initial enforcement action.
For 500 and 700 Enforcement Action Types:
FA Final Monetary Penalty. The amount of the total penalty in
dollars a handler named in an enforcement action must pay
directly to the responsible agency.
RCRIS
CEE PEN TYPE
Basic
Implementing
organization
A-25
-------
Name
Type of Penalty
Amount Indicator
(continued)
Penalty Amount
Multimedia Code
Waste Quantity Unit
of Measure
Quantity Generated
Current Year
Generator Status
Definition
For 600 Enforcement Action Types :
FA Final Monetary Penalty. The amount of the total penalty in
dollars a handler named in an enforcement action must pay
directly to the responsible agency.
FC Final SEP Cost. The final amount cited in an enforcement action
as the cost in dollars to the handler of a supplement
environmental project.
CR Final SEP Credit. The credit in dollars allowed by the agency
for the completed SEP and applied towards the total final
settlement amount.
For 800 Enforcement Action Types :
No penalties should be associated with this type of enforcement action.
The dollar amount associated with the Type of Penalty Indicator field.
Code which indicates the medium or program other than RCRA
participating in the enforcement action.
BRS DATA
Unit of measure used to report quantity of the waste stream received by a
site (Form WR) or generated by a site (Form GM).
The total quantity of the waste that was generated during the reporting
year.
Code indicating the current generator status during the current reporting
year (i.e., LQG, SQG, CESQG, non-generator).
Source Code
RCRIS CEE_PEN_AMT
RCRIS CEE_MM_CODE
BRS WST_QTY_UOM
BRS GEN_QTY
BRS GEN_STS
History
Basic
Basic
Basic
Basic
Basic
Owner
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
Implementing
organization
A-26
-------
PARTA-2: RECOMMENDED DATA ELEMENTS THAT
ARE NOT CURRENTLYMANDATORY CORE/NATIONAL DATA
(These data elements are under development; precise definitions are not yet available.)
Name
GPRA enforcement
and compliance
assurance facility
baseline
GPRA enforcement
and compliance
assurance high
priority areas baseline
GPRA enforcement
and compliance
assurance small
business baseline
GPRA enforcement
and compliance
assurance use of
incentive policies
GPRA enforcement
and compliance
assurance use of PPAs
On-Site Handling
Off-Site Handling
Reduce PBT
chemicals in
hazardous waste
streams;
baseline
Definition
RCRISDATA
All hazardous waste facilities that are actively managing waste.
All hazardous waste facilities that exist in high risk areas or where
populations are disproportionately exposed (Environmental Justice).
All hazardous waste facilities that are considered small business entities
that receive relief under the small business policy.
The use of enforcement and compliance assurance incentive policies by
the regulated communities and federal facilities.
PPAs that include joint planning and priority setting for Enforcement and
Compliance Assurance.
BRS DATA
Code indicating if the waste described was treated, disposed, or recycled
on site or discharged to a sewer/POTW.
Code indicating whether waste described in Section I was shipped off site
during the current year.
Percent reduction of the most persistent, bioaccumulative and toxic
chemicals in hazardous waste streams.
1991 GPRA baseline quantities.
Source Code
RCRIS New - will be
added
RCRIS New - will be
added
RCRIS New -will be
added
RCRIS New -will be
added
RCRIS New - will be
added
BRS ON_SITE_MANG
BRS OFF_SITE_SHP
TRI/BRS N/A
History
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Owner
OECA
OECA
OECA
OECA
OECA
Implementing
organization
Implementing
organization
HWMMD
A-27
-------
Name
Increase amount of
hazardous waste
safely recycled;
baseline
Reduce combustion
emissions;
baseline
Definition
Tonnage and percent increase in the amount of hazardous waste safely
recycled based on the amount safely recycled in 1993.
Percent of hazardous waste safely recycled in 1993.
OTHER
Receipt of certification; certification is received on date receiving
organization logs it in.
1 994 hazardous waste combustor emissions of dioxons/furans, particulate
matter, and acid gases.
Source Code
BRS N/A
HQ Combustion N/A
Database
1
History
Basic
Basic
Owner
HWID
To be
determined
A-28
-------
APPENDIX B.
LIST OF ACRONYMS
AA Assistant Administrator
AG Attorney General
APP Annual Performance Plan
ASTSWMO Association of State and Territorial Solid Waste Management Officials
BRS Biennial Reporting System
BYP Beginning of Year Plan
CA County Attorney
CAO Corrective Action Oversight
CC Coordinating Committee
GDI Case Development Inspection
CEI Compliance Evaluation Inspection
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CIRMD Communications, Information, and Resource Management Division
CESQG Conditionally Exempt Small Quantity Generator
CM Corrective Measure
CME Comprehensive (Groundwater) Monitoring Evaluation
CMI Corrective Measures Implementation
CMS Corrective Measures Study
CSE Compliance Schedule Evaluation
DA District Attorney
DOJ Department of Justice
ECOS Environmental Council of States
EPA Environmental Protection Agency
ERP Enforcement Response Policy
ESC Executive Steering Committee
FRR Financial Record Review
GAO Government Accounting Office
GPRA Government Performance and Results Act
(Form) GM Generation and Management
GW Groundwater
HMA Handler Monitoring and Assistance
HSWA Hazardous and Solid Waste Amendments
HWID Hazardous Waste Identification Division
HWIR Hazardous Waste Identification Rule
HWMMD Hazardous Waste Minimization and Management Division
IEM Information Engineering Methodology
B- 1
-------
LIST OF ACRONYMS (continued)
1MB
IS CA Orders
ISP
LQG
MCL
MISWD
MOA
MSWLF
NCAPS
NEPPS
NRR
OAM
OCFO
OECA
OMOA
OSW
OSWER
P2000
PAA
PARS
PBT
PC
PCA
PEPAA
PIT
POTW
PPA
PPG
PSPD
RA
RCRA
RCRIS
RECAP
REI
RFA
RFI
RIP
Information Management Branch
Interim Status Corrective Action Orders
Information Strategy Plan
Large Quantity Generator
Maximum Contaminant Level
Municipal, Industrial, and Special Waste Division
Memorandum of Agreement
Municipal Solid Waste Landfills
National Corrective Action Priority System
National Environmental Performance Partnership System
Non-Financial Record Review
Operation and Maintenance Inspection
Office of Chief Financial Officer
Office of Enforcement and Compliance Assurance
Overarching Memorandum of Agreement
Office of Solid Waste
Office of Solid Waste and Emergency Response
Partnership 2000 Pilot System
Program Area Analysis
Program Accomplishments Report System
Persistent, Bioaccumulative, and Toxic
Personal Computer
Permitting and Corrective Action
Program Evaluation Program Area Analysis
Permits Improvement Team
Publicly Owned Treatment Works
Performance Partnership Agreement
Performance Partnership Grant
Permits and State Programs Division
Regional Administrator
Resource Conservation and Recovery Act
Resource Conservation and Recovery Information System
Reporting for Enforcement and Compliance Assurance Priorities
Reinventing Environmental Information
RCRA Facility Assessment
RCRA Facility Investigation
RCRA Implementation Plan
B-2
-------
LIST OF ACRONYMS (continued)
SIC Standard Industrial Classification
SNC Significant Non Compiler
SPL Sampling Inspection
SQG Small Quantity Generator
TRI Toxics Release Inventory
TSD Treatment, Storage, or Disposal
UID Universe Identification
WAM Waste Activity Monitoring
WIN/INFORMED Waste Information Needs/Information Needs for Making Environmental Decisions
(Form) WR Waste Received
B-
-------
APPENDIX C.
ESC POSITION ON PE RECOMMENDATIONS
The WIN/INFORMED Executive Steering Committee (ESC) is responsible for making the final
determination on recommendations contained in this report. ESC members include senior managers
from states and EPA who represent their individual organizations. The ESC reviewed the PE final
report and collectively supports all recommendations with some comment. The states, EPA regions
and EPA headquarters' Offices of Solid Waste (OSW) and Enforcement and Compliance Assurance
(OECA) ESC members have the following comments for the record.
State Position
The states agree with Recommendation 1 for a base set of national data elements for plans,
grants, and evaluations but would like clarification that states currently are not required to report
numerical data for certain GPRA measures, and that this report does not change state GPRA or core
measures reporting requirements. There is general support for Recommendations 2, 3 and 4 dealing
with automated systems, noting: (1) a system to track the hazardous waste management program
outlined in recommendation 2 is a good idea conceptually, (2) there is uncertaintly about the level of
increased efficiencies that may be gained from the P2K system mentioned in recommendation 3, and
(3) recognizing issues with the existing information systems found in recommendation 4. The States
strongly agree with recommendations 5 and 6 (ranking of national priorities and timely issuance of
guidance documents, respectively). While there is support for Recommendation 7 dealing with
streamlining current hazardous waste planning processes, the states found it difficult to assess.
Regional Position
The Regions support all recommendations with comment on Recommendation 2 questioning
whether development of a national automated system to track hazardous waste program progress is the
best use of resources given other individual organizations' potential effort to develop such a system.
Headquarters OECA Position
OECA supports all recommendations with comment on Recommendations 5 and 7. For
Recommendation 5, OECA notes that any emerging system(s) should accommodate multiple priorities
since it may be difficult to rank priorities between OSW and OECA due to differing program practices.
Recommendation 7 recommends that plans not in use should be eliminated, OECA notes all their plans
are used.
C-l
-------
OSW Position
OSW supports all recommendations without comment.
C-2
------- |