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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                  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)
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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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