vv EPA
United States Office of October 1989
Environmental Protection Solid Waste
Agency Washington, DC 20460
Development
Decision
Paper
EPA
530
1989.9
RCRIS
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/ INTRODUCTION
Purpose
The purpose of this document is to summarize the achievements and remaining
t challenges associated with RCRIS (the Resource Conservation and Recovery
J Information System) as it stands at the threshold of national implementation.
^
Steering Committee Decision Requested
OSW is requesting that the Steering Committee approve the commencement of
national implementation of RCRIS in October 1989.
Previous Steering Committee Reviews
• Approval of System Concept August 1986
• Review & Endorsement of Prototyping Approach,
Design and Development Phases December 1986
• Review of Status and Revised Schedule June 1987
• Approval of ASTSWMO Package December 1987
• Review of Status and Schedules December 1988
* Status Report, Review of Pilot Approach and
Proposed National implementation Plan March 1989
STATUS OF IMPLEMENTATION
The RCRIS Concept
RCRIS has been developed cooperatively by EPA Headquarters, Regions, and
States to track a wide range of RCRA-related information. The system
organizes data on RCRA regulated facilities into the following categories (1)
handler identification; (2) permitting, closure, and post-closure; (3)
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compliance, monitoring, and enforcement; (4) corrective action; (5) program
management; and (6) facility management planning. RCRIS was written in
FOCUS and is designed to work on the variety of hardware/software
configurations typically found in Regional and State offices. Its two-domain
concept is aimed at meeting the dual information needs of RCRA implementers
and EPA oversight personnel with efficiency and flexibility.
Current Status
The viability of RCRIS was confirmed in several demonstrations, field tests,
and evaluations over the past year. Potential users are awaiting nationwide
implementation of the system, especially after the pilot test conducted in
Region IV this spring. The system has been fine-tuned on the basis of pilot
results, and plans for user support and change management are fully developed.
RCRIS is ready for implementation.
PILOT TESTING
The Pilot in Region IV tested the system on diverse platforms. Between March
27, 1989 and June 30, 1989, each of four Region IV States piloted a different
system architecture suitable to its current or desired data collection approach.
Additionally, Region IV piloted the system as a Regional representative. The
platforms tested were:
Georgia:
Mississippi:
Florida:
Kentucky:
Region IV:
Logical mainframe
IBM-compatible PC
"Translator" software converting RCRA data into
RCRIS format for reporting to EPA
Manual (e.g., paper records sent to the Region
for entry into RCRIS)
Logical mainframe
During the Pilot, Region IV, Kentucky, and Georgia also implemented RCRIS on a
Personal Computer. The Region implemented on a Personal Computer in order
to facilitate its training, and support its PC-implementing States. Kentucky
and Georgia both decided to use a Personal Computer in order to form a basis for
comparison for making their final implementation choice.
Although the Pilot officially ended on June 30, 1989, all of the Pilot States
opted to continue using RCRIS and provided continuous feedback over the
summer as changes were made to the software, documentation and training
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materials. For National Implementation, Kentucky has decided to use a personal
computer, instead of the platform originally piloted.
POST-PILOT TROUBLESHOOTING
Pilot participant evaluations of the system proved invaluable for correcting and
improving RCRIS in preparation for national implementation. The four major
concerns raised by the Pilot participants were:
• Response time of the software
• Various system "bugs"
* Training and documentation
• Telecommunications
OSW devoted considerable resources to resolving these issues by the end of FY
1989.
• RESPONSE TlME-Major progress has been made toward improving the
response time on the PC. For example, the processing time for
inputting notification to the Handler ID Module has been better than
halved. Also, the distribution of RCRIS programs into subdirectories
has significantly improved the operating time for each module. IBI
(creators of FOCUS) and the National Data Processing Division (NDPD)
have been working together to resolve response time problems on the
Logical Mainframes. A 30% improvement on response time has been
realized in the Handler Identification (HID) module on the Logical
Mainframe platform. IBI has made suggestions for more improvement
as time permits. The improvements made to the HID module will be
duplicated throughout the system.
* SYSTEM BuGS-As various "bugs" are discovered and reported, the
RCRIS programmers have set to work on resolving them. This will be a
continuing effort before and during national implementation. Within
the last year, the Permitting, and Compliance Monitoring and
Enforcement Modules, and the Notification portion of the Handier
Module, have been completely rewritten to eliminate "bugs" and
increase the response times. Other modules are also being corrected
based on testing and pilot results.
• TRAINING AND DOCUMENTATiON-Current status on these is treated in
the next section: "User Support."
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* TELECOMMUNiCATiONS-This area continues to be a challenge. Specifics
are discussed below under "Implementation Decisions and Issues."
USER SUPPORT: UPDATED AND ACCESSIBLE
Responses from users during the RCRIS pilot test helped the RCRIS team outline
its User Support program. User Support activities include:
• User Support Hotline
• User Bulletin Board
• User Group Meetings
• Training
» Documentation
The User Support Team is composed of members of the RCRIS testing team.
Fully briefed on the system, these individuals are ready to support users with
all the tools described below, as well as aid in change management.
• RCRIS HOTLINE-The RCRIS Hotline -- 1- (800) 767-RCRI --will be
the first point of contact for all user problems and change requests.
The hotline will be staffed by members of the testing team.
• RCRIS BULLETIN BOARD - A computerized RCRIS Bulletin Board
(Tradepost), accessible via normal telecommunication lines, is being
established to facilitate communications and individual problem
solving between users.
• RCRIS USER GROUP MEETINGS - EPA will sponsor national RCRIS user
group meetings twice a year, as well as an annual Washington, D.C.
seminar for RCRIS users employing translator software. In addition,
training will be offered at other RCRA-related conferences and
meetings.
• TRAINING — The RCRIS training team will bring one week of intensive
training to each Region in FY 1990. There will also be a follow up
week-long training trip to each Region approximately six months after
initial implementation. The training courses are interactive and will
be tailored to the individual needs of trainees, e.g., Database
Administrators, Data Entry Operators, RCRA Staff, Manual
Implementation Staff, or RCRA Program Managers. The schedule for the
training week is attached.
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Trainers will encourage questions from the trainees. The discussions
will be reinforced by hands-on exercises. These discussions will offer
the advantages of immediate practice and troubleshooting within an
environment that stimulates interest in overall system capabilities.
Each trainee will receive a Student Guide and Exercise Booklet that
will provide the training framework. Course materials are designed to
be annotated by students as the training progresses and to serve as
reference materials long after the week has ended.
• DOCUMENTATION - The RCRIS documentation has been completely
revised to incorporate the changes, corrections, and additions
suggested by the Pilot participants. In particular, the Pilot
participants requested more explanatory information and inclusion of
all screens in the User Guide. As the new documents become available,
they are being placed on the IBM 3090 at Research Triangle Park for
online distribution. Key documents include: Start-Up Guide, User's
Manual, Data Element Dictionary, Database Administrator's Handbook,
Conversion Technical Specifications and functional requirements.
CONFIGURATION MANAGEMENT
Enhancement and maintenance will be assured via a configuration management
strategy developed to encourage continued Regional and State input into future
system operations and modifications. The RCRIS configuration management
process will be structured as follows:
• A representative Configuration Management Board, supported by
workgroups, will review programmatic and technical issues and make
preliminary decisions about modifying and enhancing RCRIS.
• The Technical Manager and Staff will analyze system bugs and order
appropriate fixes. They will also facilitate the activities of the
Configuration Management Board and the workgroups.
• A Central Problem Management System (CPMS) will offer an
automated tool for tracking user requests from the identification of
problems to the release of revised or enhanced RCRIS software.
• Bi-annual National User Group Meetings will foster communications
between RCRIS partners and provide a forum for raising issues and
suggesting RCRIS modifications and enhancements.
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The complexity inherent in the range of platform choices offered by RCRIS
creates special challenges for change management These are discussed below
under "Implementation Decisions and Issues."
RCRIS: Ready For National Implementation
RCRIS is ready for national implementation. The States and Regions are anxious
to begin implementation. This is evident in the fact that 39 States have
requested implementation in the first year. OSW anticipates completion of
national implementation by FY 1992:
FY 1990: 10 Regions and 39 States
FY 1991: 12 States
FY 1992: 1 State
By the end of FY 1991, all States will be reporting in RCRIS format. Parallel
operations of HWDMS and RCRIS will be completed by the end of FY 1992.
During the course of the Pilot, the National Data Processing Division (NDPD) has
provided extensive support to the RCRIS effort. They have readily responded to
problems that have arisen about IMF space limitations, LMF utilization and
telecommunications. NDPD has re-asserted its commitment for the successful
implementation of RCRIS.
IMPLEMENTATION DECISIONS AND ISSUES
There is only one implementation decision at this point: whether to begin the
national implementation of RCRIS, or not to begin national implementation.
RCRIS Project Management believes that the system is ready, but admits that
RCRIS - like most endeavors of this type and magnitude - has not developed
trouble-free. The sections below summarize the challenges that still face
RCRIS and the approaches being undertaken to address them.
Annual Changes to SPMS Logic
Every year, the select logic used in the SPMS measures are modified by EPA
Headquarters. Since SPMS is one of the tools used by EPA in evaluating
program progress and affects the allocation of funding, the accuracy of the
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SPMS reports are crucial. Due to the diversity of platforms inherent in the
RCRIS system, modifications to the software will take three to six months to
implement. Therefore, the updated SPMS logic must be received by the RCRIS
Headquarters Support Staff six months prior to the beginning of the Fiscal Year.
In other words, EPA Headquarters must agree to provide the revised SPMS logic
by the middle of March of each year in order for it to be used in the first quarter
of the fiscal year.
Acceptance of the Two Domain Concept
The two-domain concept on which RCRIS is based requires a no "tinkering"
policy on the part of the Regions. The Regions must accept their oversight role
and become willing to rely on the accuracy of data generated by implementers.
The ownership of the data should be specified in the Memoranda of
Understanding between the Regions and States. Any disagreements over data
will have to take the form of negotiation, discussion, and mutually agreed-upon
changes.
Changes to the Universe Calculations
In the process of implementing RCRIS, the universe of waste-handling facilities
will change. The current universe numbers for transporters, fully-regulated
generators, land disposal facilities, incinerators, storage/treatment facilities,
and small quantity generators are represented by subjective fields in the
HWDMS database.
These universe indicators are calculated in RCRIS based on other data such as
regulatory status and process codes. These indicators can not be changed if a
discrepancy exists between EPA and a State. The Implementer of Record for
that data (State or EPA) will own the data and that view will prevail.
These "universe calculations" are used by EPA in determining the allocation of
Regional staff and federal grant monies to the States. States and Regions fear
that gaining control of their data will serve to punish rather than reward them
by reducing their funding levels if the new RCRIS numbers are used.
Resources
The Regions must set aside five percent (5%) of the total Regional grant
allocations to support RCRIS activities in the States. This puts the States in a
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good position to undertake national implementation. The Regions, however, do
not have the level of resources necessary, especial!/ in the area of personnel
and timeshare costs.
The resources deficiency is especially keen for the Regions that will have to
work with both HWDMS and RCRIS data through the end of 1991 while their
States phase in RCRIS implementation. This parallel operation of systems will
put a severe strain on the Regions' personnel resources. Toward that end, OSW
has requested additional funding for the Regions to cover the additional costs
involved in parallel operation.
Timely Response to Change Requests
The very design features that make RCRIS attractive and effective are likely to
complicate the change management process. Since RCRIS exists on three
distinctly different platforms (the Personal Computer, the Logical Mainframe
and the IBM 3090 Mainframe) and because RCRIS serves the needs of such
diverse users as State and Regional Implementers and Regional and
Headquarters oversight staff, the process for the review of modifications to the
RCRIS system will have an extended lag time. Every change must be reviewed
for it's impact on each set of users and each platform. Furthermore, because of
the tremendous number, as well as variety of users, the modifications that are
made will take time to be distributed and fully implemented nationwide.
The release of modifications and new versions will be carefully managed and
controlled by the EPA Headquarter's RCRIS staff. A RCRIS librarian will be
responsible for releasing these changes and for making sure that changes made
to the software are properly documented. Users will be informed of the
complexity of the task of modification, and will be notified of system
modification progress as necessary.
Telecommunications Challenges
Telecommunications is a challenging task. Although the Agency's State/EPA
data management initiative has ensured a link from each State to the EPA
network, the RCRIS users are in different locations within the State. Without a
secure telecommunications network, the implementers will be unable to
transmit their data to the Regional oversight/merged database.
NDPD is working with the RCRIS staff to ensure that each State has a secure
telecommunications link. By the end of calendar year 1989, NDPD will have
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completed installation of high speed telecommunications lines for all the
Regions. These lines should improve the distribution of RCRIS software to the
Regional LMFs.
Unauthorized Modifications to the RCRIS Source Code
At the request of the National Governors' Association and the States, OSW will
be releasing the RCRIS source code to the Regions and States. Unfortunately, by
doing so we may be creating additional problems. Armed with the source code,
States and Regions will be able to modify the program - by either adding or
deleting sections - at will. These unauthorized modifications will cause two
problems: 1) User Support will not be able to be as effective at trouble
shooting problems that arise from individual modifications, and, 2) when new
versions of the software are released and installed, the State or Regional
changes will have to be reprogrammed.
One approach to help User Support weed out possible problems is the
telecommunications package Carbon Copy. Carbon Copy will allow User Support
to call into a troubled system and, by checking the size of the compiled
programs, determine if the system has been modified by the State or Region.
EPA Headquarters will inform all State and Regional users that any modification
to the system will cause the problems listed above and is strongly discouraged.
RESOURCE REQUIREMENTS
Projected contract costs for the next three fiscal years are $3.5 million for
FY90, $3.5 million for FY91 and $3.0 million for FY90. In additon to contract
dollars, timeshare costs are estimated at $2.7 million in FY90, 2,0 million in
FY91 and 1.5 million in FY92. The timeshare costs for FY90 were projected
using a timeshare model based on pilot usage. The bulk of the cost is to
accomodate several conversions of HWDMS data into RCRIS to aid in data
cleanup. A breakdown of FY90, FY91 and FY92 costs are as follows:
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FY90
FY91
FY92
Management Support
and Outreach
Development and Maintenance
Implementation and
Enhancements
Documentation, Testing and
User Support
Technical Support
Training
Sub-Total
Ti mesh are Costs
Total
$ 850,000 $ 850,000 $ 850,000
550,000 350,000 100,000
400,000
600,000
700,000
400.000
3,500,000
2.700.000
500,000
600,000
700,000
500.000
3,500,000
2.000.000
450,000
400,000
700,000
500.000
3,000,000
1 .50Q.QQQ
6,200,000 5,500,000 4,500,000
BENEFIT/COST EVALUATION
The Management Decision Paper, prepared for the August 1986 Steering
Committee Meeting, contained a benefit/cost analysis of the RCRIS System.
The analysis concluded that the RCRIS System, incorporating the Two Domain
Concept, was the most cost effective option available to fulfill the objective of
creating an information management system capable of supporting the RCRA
program. While implementing the Two Domain Concept would result in higher
development costs due to the complexity of providing a system for such diverse
platforms as personal computers and mainframes, these costs would be more
than offset by savings to the States who would otherwise develop their own
systems. Additionally, RCRIS would provide for data sharing between EPA and
the States which promotes a higher level of data quality.
Since the original analysis, the basic benefit and cost factors remain relatively
unchanged. OSW believes that the expenses to be incurred for RCRIS in the next
few years will be justified by the increased usefulness of the data received by
Headquarters to track and monitor the RCRA program.
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RELATED RCRIS DOCUMENTATION
System Concept
Management Decision Paper
System Design Paper I - Synopsis
Concept Paper for Data Administration
Project Management Plan
Design Decision Paper
Communications Strategy
Security Plan
Executive Summaries
Planning for Implemenation:
An Executive Summary
National Implementation:
An Executive Summary
Documentation
Documentation Standards
Guide to Documentation
User's Manual
Database Administrator's Handbook
Training Manual
Data Element Dictionary
JOR/MOU
Model EPA/State Memorandum of
Understanding
Implementer of Record Policy
Implementation
Implementation Planning Materials
State Implementation Plan Outline
Pilot Implementation Plan
Strategy for National Implementation
Regional and State Implemenation
Plan Summary
Framework for National Implementation
September 1985
August 1986
December 1986
September 1987
June 1988
August 1988
August 1988
January 1989
July 1988
September 1989
December 1988
February 1989
October 1989
October 1989
October 1989
October 1989
November 1988
November 1988
December 1988
January 1989
March 1988
March 1988
April 1989
August 1989
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Configuration Management
Configuration Management Plan January 1988
Configuration Management Board
Charter and Process (Draft) October 1989
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