vv EPA United States Office of October 1989 Environmental Protection Solid Waste Agency Washington, DC 20460 Development Decision Paper EPA 530 1989.9 RCRIS ------- a ,0 '• l / 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) en o> rr -JfUfiO ------- 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 ------- 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." ------- * 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. ------- 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. ------- 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 ------- 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 ------- 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 8 ------- 1 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: ------- 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. 10 ------- 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 11 ------- Configuration Management Configuration Management Plan January 1988 Configuration Management Board Charter and Process (Draft) October 1989 12 ------- |