RCRA
  RCRAInfo Change Management Process
             Final Document
               Prepared by:

   RCRAInfo Change Management Process Workgroup
 for distribution to the National RCRA Program Community
               Approved by:

WIN/INFORMED Executive Steering Committee July 28,2005
             November 14, 2005

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Table of Contents


     Background	3

     Workgroup Scope	3

     Acknowledgements	4

     Introduction	4

     Process Recommendations	5
         Figure 1: Flowchart Process for an Operation & Maintenance Request	7
         Figure 2: Flowchart Process for a Streamlining Request	8
         Figure 3: Flowchart Process for a Program, Guidance & Regulatory or
                   Major Enhancement Request	9
         The Step by Step Process	10


     Process Implementation	11

     Roles and Responsibilities	13

     CMP Group Member Selection Process	18

     Conclusions	19

     Appendix A:  Acronyms and Abbreviations	20

     Appendix B:    Estimated Timeframes for
                   Implementing Change Requests	21



     Volunteer Response Form for  CMP Group Membership	23

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BACKGROUND

The Waste Information Needs/Information Needs for Making Environmental Decisions (WIN/INFORMED)
initiative originated in 1994 as a partnership between EPA and the States when the EPA's Office of Solid Waste
(OSW) included an information management objective as part of its five-year Strategic Plan for the RCRA
Subtitle C (RCRA C) program. The objective noted that the RCRA C program should be "information driven,"
and there should be a close connection between strategic goals for the RCRA C program and information
available in the national data system, RCRAInfo. The overall vision for the WIN/INFORMED initiative was to
integrate information management as a regular part of program development, program implementation, and
program evaluation, while making reporting and using hazardous waste information as easy as possible.

The goal of WIN/INFORMED was to analyze the RCRA C information needs and then design the data system
to provide the required information. WIN/INFORMED laid out a logical 5-stage process for defining RCRA C
information needs and implementing changes to the data system:  1) planning, 2) analysis, 3) design, 4)
construction, and 5) ongoing maintenance. The last stage, the ongoing maintenance phase, is as vital as the first
four. Ongoing maintenance of the data system, including required system upgrades  and enhancements, will
need to continually take place to ensure RCRAInfo keeps pace with the changing information needs of the
RCRA C program.

The WIN/INFORMED program analyses will end the Summer of 2005 and then ongoing maintenance of the
RCRAInfo data system and related data collections is required to address the changing information needs for
the RCRA C program.  The last Program Area Analysis Report (permitting and corrective action) is completed
and work is underway to re-design that system as required by the recommendations.
WORKGROUP SCOPE


The RCRAInfo Change Management Process (CMP) Workgroup was formed by the WIN/INFORMED
Executive Steering Committee (ESC) to develop the process by which future changes to RCRAInfo will be
determined, following the implementation of system changes required by the recommendations of all
WIN/INFORMED Program Area Analyses (PAAs).

The CMP Workgroup was tasked with developing a streamlined change process which will allow all
stakeholders to have an opportunity to submit change requests and suggestions, while also allowing all
stakeholders a voice in deciding which system changes are implemented with the resources available to HQ
OSW.

The workgroup was responsible for defining the issues, analyzing solutions, and proposing a process to the
stakeholders for consideration. Issues discussed by the Workgroup included the:

             •   need for timely implementation of changes in the data system;

             •   level of effort and resources required to implement an ongoing change management process into our
                daily routines;

             •   requirement to report and track ALL future change requests using the new (to be released in
                RCRAInfo V3) RCRAInfo User Support Issue Tracking System (USITS); and

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                need for RCRA C program and information management staff to continue to overcome "culture
                change" issues by improving communication and coordination for emerging RCRA C program
                changes that will impact information use and the data system.
ACKNOWLEDGMENTS

The RCRAInfo Change Management Process Workgroup is comprised of representatives from all major
stakeholders in the process. This proposed RCRAInfo Change Management Process was developed by all
members of the Change Management Process Workgroup:

      •   Dan Bakk, US EPA Region 5  (Workgroup Co-lead)
      •   Debbie Goodwin, US EPA OECA
      •   Lynn Hanifan, US EPA Region 1 (Workgroup Co-lead)
      •   Cindy Harmon, Arkansas
      •   Laura Lopez, US EPA OSW
      •   Jan Martin, US EPA Region 4
      •   Mira Neumiller, Colorado
      •   Linda Prockish, Kansas
      •   Dina Villari, US EPA OSW (Workgroup Co-lead)
INTRODUCTION
This report presents the proposed RCRAInfo Change Management Process (CMP) to provide timely controlled
changes to RCRAInfo. These recommendations will facilitate and promote a more responsive and committed
effort toward maintaining high quality information to support RCRA C program activities. Like the
WIN/INFORMED initiative, the proposed CMP continues the partnership between EPA and the States. For
successful implementation of this new process, it is critical that all members of the RCRA C Community
recognize the CMP as the only mechanism for reporting and evaluating the need and resources available
to implement changes to the RCRAInfo data system.

Since the new CMP must include the process for managing new or changing information needs of the RCRA C
program, the CMP was designed to meet the needs of both the RCRA information management community
and the RCRA program management community.  These distinct, but often over-lapping, entities could also
be called "system users" and "data users"  System users are those users who both "input information" into
the RCRAInfo system and "extract information" they require from the RCRAInfo system.  They maintain the
data system and work with data, but generally do not apply data for a specific purpose. In general, system
users often perform activities such as:  entering data, deleting data,  reorganizing data, receiving data from the
RCRA C regulated community, transmitting data, extracting data, reporting system problems or "bugs", running
standard national or implementer-defined reports,  and developing custom reports to meet their organization's
reporting requirements. "Data users" primarily "extract information" they require from the RCRAInfo
system, and are users who run standard and customized reports to work with the data and apply it to setting
goals, answering questions, solving problems, quantifying accomplishments, prioritizing workload, making
decisions, and monitoring progress.

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Data users in the States and EPA Regional offices often use the data to: provide RCRA site descriptions and
activities related to regulated wastes; identify which sites and facilities to inspect; prioritize a permitting
workload;  evaluate performance of States regarding implementation of the RCRA C program; examine waste
quantities and waste flow; understand the history of a particular facility; provide facility specific information to
the public; track the effectiveness of legal instruments; monitor progress of a specific facility or State toward
GPRA goals; prioritize facility workload; respond to information requests; show programmatic efforts to the
public, state legislature and/or executive bodies and summarize and validate accomplishments.

Data users in EPA Headquarters will usually perform activities such as: proposing information requirements
to implement voluntary or regulatory efforts; providing RCRA site descriptions and activities related to
regulated wastes; estimating regulated universes for regulatory development and Information Collection
Requests (ICRs); responding to public inquiries/FOIAs; investigating reductions in reporting/record keeping
burdens; recommending data quality improvements; finding analytical uses for and limitations with the data;
developing GPRA goals; designing GPRA measurement processes; planning for the Resource Conservation
Challenge  (RCC) initiative; providing RCRA C strategic planning analyses; and targeting constituents and
facilities for waste minimization.

The overall vision for the WIN/INFORMED initiative was to more fully integrate the RCRA C program to
facilitate communication between the information management system and the RCRA C program, and to
integrate information management as a regular part of program development, program implementation, and
program evaluation.  To successfully implement this vision, requires continued efforts to enforce a "culture
change" in the RCRA C Community to establish better coordination/communication regarding new or changing
RCRA C program issues. In other words, all types  of "system users" and "data users" must communicate with
each other on  a regular basis to ensure the data system can continue to capture the information required to
support and implement the RCRA C program. From the analysis conducted by the CMP Workgroup, this
"culture change" is required in all organizations- EPA Headquarters, EPA Regions and in the States.  To
support and facilitate this culture change, the following process recommendations were developed.
PROCESS RECOMMENDATIONS

The RCRAInfo CMP was developed by the Workgroup to:

       1) identify required or desired changes to the nationally maintained RCRAInfo data and software;
       2) facilitate consideration of the requested change by the national user community;
       3) facilitate communication between program and information management staff; and
       4) track all RCRAInfo change requests from receipt through resolution.
Version 3 of RCRAInfo will include a new component of RCRAInfo, the User Support Issue Tracking System
(USITS), to facilitate the new CMP  USITS is the tool that will be used by the entire RCRA C Community
to initiate a request for change and will be instrumental to the success of the new RCRAInfo Change
Management Process.  USITS was designed and developed by OSW's RCRAInfo Programmers to allow the
RCRA C Community to enter and track the status of all issues, change requests, and system bugs that are
identified by the Community. USITS will be accessible through RCRAInfo and designed to allow all
RCRAInfo Users to comment on all CMP requests before they are approved or denied.  As the RCRA C
Community submits requests for change through the CMP, these changes will be reviewed by the USITS
System Administrator (SA) and categorized into the appropriate change management types identified below:

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The CMP Workgroup identified 4 major types of changes:

       Operations and Maintenance of the National System and National Database: changes required to
       fix current programming errors/bugs; adapting the existing system to meet current and upcoming
       technological requirements; and updating system and/or user documentation.

       Streamlining: short-term, low-cost, low level-of-effort changes to the national data system and/or
       database that result in minimum changes to our daily routines to incorporate the changes. (Examples:
       Adding or deleting event codes, field sorts, screen views, button placements, Denial of obviously
       superfluous, impractical requests, and changes to HQ Management Reports.)

       Program, Guidance and Regulatory: proposals requesting changes to RCRAInfo to address new or
       changing information needs for the RCRA C program.

       Major Enhancements: proposals requesting changes to the national data system and/or database,
       however, the suggested change does not meet the criteria to be classified as "Streamlining".
The anticipated timeframes to reach final recommendation for each type of request is in Appendix B
with Streamline and O&M requests taking 2 V2 months and Program, Guidance, Regulatory, and
Major Enhancements taking 6 months.

The CMP flow chart on the following page illustrates the CMP Workgroup's proposed flow of change
issues through the process.  Immediately following the chart, you will find the recommended steps that
each change type will follow to assist you in reading and understanding the chart.

The flow chart is interactive with the document. Each flowchart links to descriptions of the steps in
the process. The definitions of the symbols are:
Symbol
User Support
Issue Tracking
System
^v Group jf
/^Hrogran^^
x.^ Graupt j^
Design
briptatientalKn
Group
Click on this symbol for a
description of group's role
in CMP:
User Support Issue Tracking
System (USITS)
Coordination Group (CG)
Program Groups (PCs)
Design and Implementation
Group (DIG)
Symbol
Operation &
Maintenance
f Streamlining
Program. Guidance &
Regulator/ Change*
Major
Enhancements

-''Trarislitiwi^v
\ Group /
XManagementv
V Boalti /
Click on this symbol for a
description of group's role in
CMP:
Any one of four major types
of changes identified by the
CMP Workgroup.
Translation Group (TG)
Management Board (MB)

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Flowchart Process for an Operation & Maintenance Request
                            Figure 1
  USER INPUTS
     INUSITS
SA EVALUATES—  USITS
 O&M
REQUEST
                                   USER
                                 COMMUNITY
- -SYSTEM FIXES

 RESOLUTION AM>
 IMPLEMENTATION
 -SCHEDULE--DIG
 COORDINATES WITH
 TG AS NEEDED
         - -NOTIFICATION

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         Flowchart Process for a Streamlining Request
                               Figure 2
   USER INPUTS
     INUSITS'

 LS1TS SYSTEM
ADMINISTRATOR
   EVALUATES
     REQUEST
   EVALUATES/
    APPROVES
     REQUEST
LSITS
                   STREAMLINING
                      REQUEST
                                        USER
                                      COMMUNITY
Low COST AND
LOE REQUEST

RESOLUTION AND
IMPLEMENTATION
•SCHEDULE - - DIG
COORDINATES WITH
TG AS NEEDED

NOTIFICATION OF
IMPLEMENTATION

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   Process for Program, Guidance & Regulatory or Major Enhancement Request
                                            Figure 3
 CHANGE
 REQUEST
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USKR INPUTS
USITS
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                               USER     _ NOTIFICATION OF
                             COMMUNITY   IMPLEMENTATION
                        I
                                i
              IMPLEMENTATION
                                                            TG
                                                                       USER
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                                                                              - RECOMMENDS
                                                                               SOLUTION
                                                                               EVALUATF.S
                                                                               SOLUTION FOR
                                                                               TRANSLATION
                                                 REVIEWS AND
                                                 SUBMITSTO
                                                 USER
                                                 COMMUNITY
                                                                   NOTIFICATION
                                                                — or PRO POSED
                                                                   CHANCES

                                                                  APPROVAL IF
                                     'i CG, PC * TG WORK TOCETHEK
                                     ^TO RF.VIRW COMMENTS A MAKF.
                                      NECESSARY MODIFICATIONS
                                                                                                    9

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Step by Step Process, the following outlines each specific step a change request will take
when "flowing" through the CMP:                           Return to Fig 1, Fig 2, Fig 3

Step 1   Change Issue/Request/Proposal (Request) entered by requesting User into RCRAInfo User
         Support Issue Tracking System (USITS).  USITS System Administrator (SA) reviews and
         categorizes all Requests and clarifies as needed.

         If Request is categorized as Operation and Maintenance (O&M):

             la-O&M Requests submitted directly to the Design and Implementation Group (DIG) for
                resolution. DIG will review and provide the RCRA C Community with an
                implementation schedule based on current resources available to implement changes.
                The Translation Group (TG) will review all O&M Recommendations.

             Ib-ALL Other Requests submitted to the Coordination Group (CG) for further review.

Step 2   CG will:

             2a-Review and Categorize Request into one of the following categories. (Historic Requests
                will be available for reference to aid CG.)

                  1.  Streamlining
                  2.  Program, Guidance & Regulation (P, G & Reg)
                  3.  Major Enhancements

             2b-If Streamlining, CG will evaluate  and approve/deny Request and notify requesting
                User and User Community. If CG approves, Request submitted to the Translation
                Group for review and comment, then to the DIG for scheduling and implementation.
            2c-If P, G & Reg Request or Major Enhancement Request, CG will designate the
                applicable Program Group (PG) and forward Request to one of five PGs listed below.
                If necessary, more than one PG will be assigned the Request.

                   1.  Corrective Action Group (CAG)
                   2.  Permit/Closure Group (PCG)
                   3.  Site Identification Group (SIG)
                   4.  Waste Activity Group (WAG)
                   5.  Compliance/Enforcement (CEG)
Step 3   Applicable PG will review, analyze and recommend how to proceed with Request (i.e., the
CAG will review Request pertaining to RCRA Corrective Action, the PCG will review Request
pertaining to RCRA Permitting/Closure).  If necessary, more than one PG will review Request.

         PG(s) forwards Request and PG Recommendation to Translation Group (TG) for review.

Step 4   TG reviews Request and PG recommendations and makes recommendations regarding
         translation issues. TG forwards Request and recommendation(s) to the CG for review.
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                                                                    Return to Fig 1, Fig 2, Fig 3
Step 5   CG reviews PG and TG recommendations and prepares Recommendation for national review.

Step 6   CG submits Recommendation to user community for national review.

Step 7   National review and comment period.

Step 8   CG, TG and applicable PG will review any comments received.  Unless Management Board
         (MB) approval required, CG approves or denies Request based on feedback from national
         review.  CG, TG and applicable PG will work together to revise Request and Recommendation
         if necessary.

Step 9
         A CG approved Request and Recommendations not requiring Management Board (MB)
            approval will be submitted to Design and Implementation Group (DIG).  CG, TG and PGs
            will work with DIG as needed.

         B Request and Recommendations which require Management Board (MB) approval will be
            submitted to the MB. MB approval may be necessary when Request requires significant
            resources to implement  system changes.

Step 10   Approved Requests and Recommendations go to DIG for implementation. CG, TG and PGs
          will work with DIG as needed.  DIG prepares an implementation schedule.

Step 11  Final Recommendation regarding Request distributed to User Community by CG with
         proposed implementation schedule.

Step 12     Request implemented as scheduled.                         Return to Fig 1, Fig 2, Fig 3
PROCESS IMPLEMENTATION

The CMP Workgroup recommends establishing the following CMP Groups to implement the CMP and provide
ongoing reviews of the RCRA C information needs identified by the RCRA C Community. Each of the CMP
Groups should be made up of data and system users. To limit the resources required to implement the CMP
(e.g., travel costs), the CMP Groups will primarily meet via Conference Calls on a monthly, or as needed, basis.
An occasional face-to-face meeting of a CMP Group may be scheduled, and future RCRAInfo National Users
Conferences will be used to conduct face-to-face CMP meetings with state funding provided by ASTSWMO.

The proposed roles and responsibilities of the CMP Group members identified below are defined in the Roles
and Responsibilities section of this document.  CMP Workgroup recommendations regarding how members of
the CMP Groups will initially be populated is discussed in the CMP Group Member Selection Process section
of this document.
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Coordination Group (CG): This group will be the main body of the Change Management Process
(CMP) and will be comprised often EPA HQ, EPA Regional, and State members (4 States, 2 Regions, 2
HQ/OSW and 2 HQ/OECA). One of the State representatives could be the Chair of the ASTSWMO
Hazardous Waste Information Management Task Force (HWIMTF).  The CG will also serve as the
decision making body for most of the issues moving through the CMP, with only those issues that
require extensive resources or major changes in RCRA C program direction having to go forward
to the Management Board (MB) for decision/approvals.  A good example of a request where the
decision could stay at the CG level would be the recent request to change the Full Enforcement Universe
with additional OP/LEG status codes. Decisions re: Streamlining requests will also be made at the CG
level.

Program Groups (PGs): The CMP Workgroup proposes five different Program Groups to handle the
various RCRA C program-specific issues received by the User Community that are considered
Program/Guidance/Regulatory type requests. Each of the PGs will be comprised of an equal number of
State and EPA members, a total of 6  (3 States, 1 Region, 2 HQ) that represent both RCRA C Program
and Information Management staff from these organizations. OECA will have 2 members  on
Compliance/Enforcement Group and OSW will have 2 members on Waste Activity Group. These 5
groups will provide in-depth analysis of change requests within their  specific program area. A request
to track something new within the RCRA C program would be considered a
Program/Guidance/Regulatory request and would be  referred to one of these groups.  The CMP
Workgroup recommends establishing these Program  Groups as  'standing' groups rather than  having the
groups 'assigned' as  needed, which will delay evaluation of the change request.  A good example of a
request that would be forwarded by the CG to the appropriate PG would  be the recent request to add a
new environmental indicator code to the RCRAInfo Corrective Action Module.  The proposed Program
Groups are as follows:

•      Corrective Action Group (CAG) - This group will handle any of the programmatic Corrective
       Action issues that are forwarded through the CMP.

•      Permit/Closure Group (PCG) - This group will handle any of the  programmatic Permitting or
       Closure issues that are forwarded through the CMP.

•      Site Identification Group (SIG) - This group will handle any of the specific site issues such as
       Notification or Part A collection information that are forwarded through the CMP.

•      Waste Activity Group (WAG) - This group will handle any issues related to the collection of
       hazardous waste activity such as that information found on the Biennial  RCRA Hazardous Waste
       Report.

•      Compliance/Enforcement Group (CEG) - This group will handle  any of the programmatic
       Compliance, Monitoring, or Enforcement related issues that are forwarded through the CMP.

Design and Implementation Group (DIG): This group will support the CMP by implementing the
changes to RCRAInfo that are identified and approved by the CG or MB. This  group will primarily
consist of HQ/OSW Information Management Branch's (1MB) RCRAInfo staff, however, this Group
will consult with the  CG and the appropriate Program Group(s) as requests for Streamlining,
Program/Guidance/Regulatory, and Major Enhancement changes  are  approved and forwarded for design
and implementation.  Consultation with the Program  Groups will allow State and Regional input into the
design process. This Group will make the necessary  changes to correct software 'bugs'  identified by the
RCRA C Community and will address other Operations and Maintenance issues as they arise.

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       Translation Group (TG): The group will have 6 members (3 States, 1 Region, 1 HQ/OSW, and 1
       HQ/OEI/CDX), and will be comprised of current or planned State translators and an EPA Region with
       translator states.  This group could develop guidelines for translation as well as ensure that everyone is
       kept informed of when new edits are added to the system. All recommendations will be reviewed by
       the TG to see if any translator issues apply. There are many states that have become Translators of some
       type of RCRA C program information that needs to be loaded into RCRAInfo. This Group would be
       responsible for commenting on any request/issue that will require a change to any of the translator
       systems. They will also ensure that system enhancements are only made once during a calendar year
       and that the User Community is notified in writing with the specifications  six  months prior to the release
       of this information.

       Management Board (MB): This group will be comprised of six members (3 States, 1 Region, 1
       HQ/OSW and 1 HQ/OECA); all key Senior RCRA C Managers within their organizations. HQ/OSW
       and HQ/OECA members will be at the Division Director or Associate Division Director level, while the
       Regional representative will be the equivalent-level Senior Manager in the Region currently responsible
       for leading all RCRA C program activities. The State representatives will  be the  Senior Manager
       currently serving as the Chair of the ASTSWMO Hazardous Waste Subcommittee, the Vice-Chair of the
       Subcommittee and a State Senior Manager designated by the Subcommittee Chair.  This group will
       generally only be called upon to evaluate and approve a change request if the CG is unable to reach
       consensus with regards to implementation of a critical Program, Guidance or Regulatory change, or a
       Major Enhancement change will require significant resources at all levels (EPA HQ, Regions and
       States) to implement. (Example:  adding a module to RCRAInfo). The group will also support the CG's
       implementation of the CMP and will discuss with the RCRA C Community changes in information
       flows to state management through the PPA, ERP or other guidance, policies and agreements.
ROLES AND RESPONSIBILITIES

The following outlines the Roles and Responsibilities of the RCRA C Community in implementing the
RCRAInfo Change Management Process.

General Roles and Responsibilities for the RCRA C Community

•      The entire RCRA C Community will be required to submit change requests or suggestions for
       operational, maintenance,  structural, report development, data calculation or information collection
       changes to RCRAInfo through the formal CMP for review and potential implementation. The
       RCRAInfo USITS tracking system will be the single source of information available to the RCRA C
       Community regarding specific RCRAInfo change requests, comments, suggestions, and reported
       problems.

•      All users are strongly encouraged to participate in the change management process. USITS will be
       designed to allow discussion and questions on all requests before they are approved or denied.

•      All state and regional users are encouraged to contact their specific state or regional RCRAInfo lead to
       discuss RCRAInfo questions or problems before submitting change requests through the CMP.
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General Roles and Responsibilities for RCRA Program Managers

•      All RCRA Program Managers, regardless of location (EPA HQ, EPA Regions or State agencies), need
       to be active users of RCRAInfo data and users of RCRAInfo data quality tools and reports. An effective
       change management process will be dependent upon the ongoing use and maintenance of RCRAInfo
       data by RCRA Program Managers and staff in all agencies.

•      RCRA Program Managers are encouraged to use the RCRAInfo CMP to request adjustments and
       enhancements in programmatic activity tracking and the ongoing reporting of GPRA accomplishments.
       Data records stored in RCRAInfo need to  present a comprehensive picture of RCRA C program
       activities and accomplishments.
General Roles and Responsibilities of State and Regional RCRAInfo Leads

•      Regional RCRAInfo leads are responsible for coordinating and consulting with their state RCRAInfo
       leads.  The CMP Workgroup recommends establishing one lead coordinator in each State and Region
       who will be given the responsibility of establishing and maintaining regular communication. An
       example of a desired communication channel is the dissemination of national RCRAInfo conference call
       summaries by regional leads to their states following each monthly RCRAInfo data call.

•      Regional and State RCRAInfo leads are also responsible for consulting with their RCRA C program
       offices on specific programmatic data needs and advising them of potential or approved RCRAInfo
       changes affecting specific data records or flows.

•      Regional and State RCRAInfo leads are expected to attend all RCRAInfo National User Conferences,
       where EPA HQ staff will provide RCRAInfo-related training.

•      Regional and State RCRAInfo leads should provide ongoing orientation and training to their
       organization's program and information management staff to encourage continued use and
       understanding of the data system by the entire RCRA C Community.

•      Regional and State RCRAInfo leads are considered one of the primary communications specialists for
       the RCRAInfo CMP, and are responsible for training and assisting RCRAInfo users in their organization
       with using USITS to submit and track  change requests.

•      Routinely monitor USITS requests and give appropriate feedback or inform others in their organization
       of potential changes as appropriate.
Roles and Responsibilities of the USITS System Administrator (SA)

•      The USITS SA will serve on the CG and will also be responsible for coordinating all CMP issues
       regarding USITS operations with the DIG .

•      The USITS SA will review all issues submitted into USITS, ensure issues are clearly stated, and will
       forward O&M issues directly to DIG and TG for resolution and implementation.
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       The USITS SA will have the lead responsibility for posting RCRAInfo alerts in USITS and other
       information related to all immediate or emergency RCRAInfo fixes and their planned implementation
       schedule.

       The USITS SA is considered one of the primary communications specialists for the RCRAInfo CMP,
       and is responsible for training and assisting RCRAInfo users in EPA HQ with using USITS to submit
       and track change requests.
Roles and Responsibilities of Coordination Group (CG) Members

•      Members will attend CG conference calls, and as required, attend face-to-face meetings to discuss CMP
       issues and change requests.

•      Members will develop a communication strategy for the CG to facilitate an ongoing flow of information
       about RCRAInfo change management topics. This includes how and to whom notification of changes
       are sent (Ex. RCRAInfo and Program Area Leads, weekly emails, and RCRAInfo news alerts).

•      Members will select a lead and co-lead person for scheduling group meetings and calls.

•      Members will distribute Quarterly status updates on the status of CMP activities.

•      Members will establish criteria for prioritizing and evaluating change requests, and requestors will have
       to provide the necessary information to the CG in their proposals. This will assist CMP Groups with
       determining the level of resources required to make the change.  The CG will distribute the general
       criteria for prioritizing change requests to the RCRAInfo user community for review and comment soon
       after the group is formed.

•      Members will review all change requests forwarded by the USITS SA and participate in decisions
       regarding the categorization of those Requests which the CG feels require further programmatic review
       by one of the 5 PGs.

•      Members will review, forward to  PG, and/or respond to questions submitted by the RCRAInfo User
       Community through USITS.

•      Members will be the decision makers/approvers regarding all RCRAInfo change
       requests/recommendations. The CG will use historic change decisions documented by the
       WIN/INFORMED process as guidance in reviewing future overlapping change requests.  Only those
       issues where consensus can not be reached amongst the CG, or where implementation of an issue will
       require significant resources or a significant change in RCRA C  program direction, will require further
       approval by the Management Board (MB).

•      CG will develop a CMP Group Replacement Strategy to ensure ongoing fair participation by those
       interested in joining one of the CMP Groups. The CG will need to consider a staggered replacement
       approach to ensure that there is always a person knowledgeable of the Group responsibilities.

•      The CG will continuously monitor and evaluate the RCRAInfo Change Management Process and
       implement adjustments to the process when necessary. Major changes will be implemented through
       annual RCRAInfo version releases on a schedule to be developed by the CG. All approved USITS
       requests will be distributed to the  RCRA C Community for notification prior to implementation.
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      National Review distribution for program, guidance, regulatory changes and major enhancements will
      be through email to the OSW RCRAInfo User Community list.

•     The goal in decision making for each Group is consensus. If consensus is not possible, majority vote
      will prevail.
Roles and Responsibilities for the Members of each Program Group

•      Each Program Group will be responsible for choosing a Group Lead and Co-lead that will lead and
       facilitate each of the 5 RCRA C Program Groups established to provide expert in-depth analysis on
       change requests related to the following RCRA C program areas: Corrective Action, Permit/Closure,
       Site Identification, Waste Activity, and Compliance/Enforcement.

•      These  5 Program Groups will act as the change specialists and recommenders for the CG on change
       requests directed to them for further review and analysis.  Their preliminary written recommendations
       for change implementation will be distributed by the CG to the entire RCRAInfo C Community for
       comments and feedback, and final recommendations for implementation will incorporate the comments
       received during these national reviews.

•      The Programs Groups will use the WIN/Informed PPA Reports as guidance and reference documents in
       review and analysis of requests.

•      Each of these 5 Program Groups will review Headquarters and Implementer-defmed RCRAInfo Lookup
       Table values annually for their specific program area to ensure consistent use of defined codes by all
       Implementers. As needed, they should create or re-emphasize data quality guidelines for users and
       should specify exceptions/QC reports to add to RCRAInfo

•      The goal in decision making for each Group is consensus.  If consensus is not possible, majority vote
       will prevail.

•      Each of these 5 Program Groups will assist the DIG on the design phase of implementing approved
       changes to RCRAInfo.

•      Each of these 5 Program Groups will also be  responsible for coordinating the development and
       presentation of future RCRAInfo training sessions focusing on their specific RCRA C program area,
       including: RCRA C program orientation training, national RCRA C program management conferences
       and the RCRAInfo National Users Conferences.  Specific training responsibilities can be delegated to
       other groups or persons under appropriate circumstances.
Roles and Responsibilities for Design and Implementation Group (DIG) Members

•      EPA HQ OSW 1MB staff will be the core members of the DIG and will have the responsibility of being
       the change coordinators and implementers for all CG and/or MB approved RCRAInfo changes.  This
       includes coordination of testing of all implemented requests with all applicable groups to verify that the
       changes are working in accordance with the recommendations.

•      The DIG will have lead responsibilities for implementing RCRAInfo O&M change requests submitted
       by the RCRA C Community via USITS.

                                                                                                 16

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       For Streamline and O&M requests the DIG will ensure that RCRAInfo relaxes edits for translators until
       the yearly annual scheduled enhancement that is allowed to affect Translator systems is done.

       The DIG will be responsible for consulting with the CG and the appropriate PG(s) as requests for
       Streamlining, Program/Guidance/Regulatory, and Major Enhancement changes are approved and
       forwarded for design and implementation.

       DIG members will be responsible for maintaining and updating RCRAInfo on-line system and user
       documentation.
Responsibilities for Translation Group (TG) Members

•      Members of this Group must be familiar with RCRAInfo translation operations and will be responsible
       for reviewing translator issues and discussing all change requests.

•      This Group will act as the change specialists and recommenders for translator issues for the CG and
       DIG. They will provide consultation to all CMP Groups for specific change requests proposed for
       implementation that necessitate changes in translation routines. Their preliminary recommendations for
       change implementation will be distributed by the CG to the entire RCRAInfo C Community for
       comments  and feedback, and final recommendations for implementation will incorporate the comments
       received during these national reviews.

•      This Group is responsible for providing the DIG with updated translator guidance for approved
       RCRAInfo changes that necessitate changes in translation routines, and the DIG will ensure the
       appropriate change are implemented in the RCRAInfo on-line system and user documentation. This
       Group will work with the DIG on identification and testing of relaxed edits.

•      This Group is responsible for obtaining input from current RCRAInfo Translator States, as well as
       coordinating discussions and interactions with EPA HQ/OEI/CDX operations group on potential
       translation changes that will impact Network Exchange activities.

•      Translator States will not be required to modify their systems to accommodate RCRAInfo
       changes more than once each year. All translation guidance changes  developed by the TG will be
       available to Translator States approximately six months prior to implementation in RCRAInfo, to allow
       sufficient time to implement the changes to the State's translation routines. Critical bugs are the only
       exception to the yearly update and six-month notice.

•      The goal in decision making for the Group is consensus. If consensus is not possible, majority vote will
       prevail.


Responsibilities for Management Board (MB) Members

•      This Group will be asked to evaluate and approve a change request if the CG is unable to reach
       consensus with regards to implementation of a critical Program, Guidance or Regulatory change,  or a
       Major Enhancement change will require significant resources at all levels (EPA HQ, Regions and
       States) to implement.


                                                                                                  17

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      The Management Board will also work to facilitate better communication between the information
      management and the RCRA C program management staff, and will enforce a "culture change" in the
      RCRA C Community to begin better coordination/communication regarding new or changing RCRA C
      program issues.

      The group is responsible for supporting the CG's implementation of the CMP and will ensure the RCRA
      C Community within their organizations follow the procedures outlined in the CMP.
CMP GROUP MEMBER SELECTION PROCESS


The following outlines the strategy developed by the CMP Workgroup to populate the CMP Groups:

•     The initial population of the CMP Groups will be conducted through use of Response Forms submitted
      during our initial review of the draft CMP document in June and July 2005, and from additional
      volunteer responses received by December 9, 2005, using the attached revised Volunteer Response
      Form.  There is no need to submit duplicate responses to volunteer.  All June and July 2005 response
      forms have been saved and will also be used to populate the CMP groups.  Those interested in
      participating on a CMP Group must obtain approval from their supervisor  prior to submitting
      your name for consideration by the CMP Workgroup.

•     During the month of December 2005 the CMP Workgroup members will select from the list of
      interested State, EPA Regional and EPA HQ/OSW and HQ/OECA volunteers and populate each CMP
      Group with the appropriate number of members representing each organization.  All initial CMP group
      members will be notified in early January 2006 of their selection. Identification and selection of
      state representatives should be made in close consultation with the ASTSWMO Hazardous Waste
      Information Management Task Force. As an on-going function, the ASTSWMO HWIMTF  should be
      responsible for recruiting/identifying state representatives. This will also serve to maintain and
      strengthen the necessary linkage between ASTSWMO (HW Subcommittee and IMTF) and EPA
      regarding information and data management.

•     The various groups should be filled with a mix of programmatic, data, and management personnel from
      the various organizations to ensure that the process is not inappropriately slanted to one perspective.

•     Once the CMP Coordination Group (CG) is formed and implementation of the CMP begins, the CG will
      develop an ongoing CMP "Group Replacement Strategy" that will address the length of time each
      Group member will serve and the method in which they will be replaced (i.e., voting vs selection).  The
      CG will be responsible for distributing the "Group Replacement Strategy" to the RCRA C Community
      for national review and comment, and will communicate the approved "Group Replacement Strategy"
      once it is final.

•     Each State or Region should have no more than one representative on each CMP Group. HQ offices
      will have more than one representative on some CMP Groups because of the need to represent different
      organization's views (e.g.,  OSW vs OECA).
                                                                                               18

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CONCLUSIONS

The overall vision for the WIN/INFORMED initiative was to integrate information management as a regular
part of program development, program implementation, and program evaluation, while making reporting and
using hazardous waste information as easy as possible. WIN/INFORMED program analyses will end the
Summer of 2005 once the last Program Area Analysis Report (permitting and corrective action) is approved and
work is underway to re-design that system component to address the recommendations.  Although the
WIN/INFORMED Initiation will be completed, ongoing maintenance of the RCRAInfo data system is required
for the changing information needs for the RCRA C program.

To successfully implement the WIN/INFORMED vision to more fully integrate the RCRA C program to
facilitate communication between the information management system and the RCRA C program, requires
continued efforts to enforce a "culture change" in the RCRA C Community to begin better
coordination/communication regarding new or changing RCRA C program issues. In other words, all types of
"system users" and "data users" must communicate with each other on a regular basis to ensure the data
system can continue to capture the information required to support and implement the RCRA C program. From
the analysis conducted by the CMP Workgroup, this "culture change" is required in all organizations- EPA
Headquarters, EPA Regions and in the States.

The CMP Workgroup was tasked with developing a streamlined change process which will allow all
stakeholders to have an opportunity to submit change requests/suggestions, while also allowing all stakeholders
a voice in making the decisions as to which system changes  are implemented with the resources available to HQ
OSW for future system changes. This document presents the CMP Workgroup's recommendations for the
RCRAInfo Change Management Process (CMP) that will provide timely controlled changes to RCRAInfo and
we feel these recommendations will facilitate and promote a more responsive  and committed effort toward
maintaining high quality information to support RCRA C program activities.

The CMP Workgroup expects initial resistance from some members of the RCRA C Community to following a
structured process for requesting and implementing changes to RCRAInfo. For successful implementation of
the RCRAInfo CMP, it is critical that all members of the RCRA C Community recognize the CMP as the
only mechanism  for reporting and evaluating the need and resources available to implement changes to
the RCRAInfo data system.
                                                                                               19

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                                         APPENDIX A


                       ACRONYMS and ABBREVIATIONS

The following is an alphabetical compilation of acronyms and abbreviations used throughout this document.

ASTSWMO - Association of State and Territorial Solid Waste Management Officials

CA - Corrective Action
CAG - Corrective Action Group
CDX - Central Data Exchange
CEG - Compliance/Enforcement Group
CG - Coordination Group
CMP - Change Management Process
CMPG - Change Management Program Groups

DIG - Design and Implementation Group

EC - Environmental Controls
EPA - Environmental Protection Agency
ESC - Executive Steering Committee

FOIA - Freedom of Information Act

GPRA - Government Performance and Results Act

HQ - Headquarters
HWIMTF - Hazardous Waste Information Task Force

ICR - Information Collection Requests
1MB - Information Management Branch
INFORMED - Information Needs For Making Environmental Decisions

MB - Management Board

O&M - Operations and Maintenance
OECA - Office of Enforcement and Compliance Assurance
OEI - Office of Environmental Information
OP/LEG - Operating and Legal Status
OSW - Office of Solid Waste

PAA - Program Area Analysis
PCG - Permit/Closure Group
PG - Program Groups

RCC - Resource Conservation Challenge
RCRA - Resource Conservation and Recovery Act
RCRA C - Resource Conservation and Recovery Act Subtitle C
RCRAInfo - Resource Conservation and Recovery Act Information System

SA - System Administrator
SIG - Site Identification Group

TG - Translation Group

USITS - User Support Issue Tracking System

WAG - Waste Activity Group
WIN - Waste Information Needs
                                                                                                        20

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                                 Appendix B
  Estimated Timeframes for Implementing Change Requests
         Estimated Timeframes for Streamlining and O&M  Requests
Streamlining: short-term, low-cost, low level-of-eftort changes to the national data system and/or database that result in minimum
changes to our daily routines to incorporate the changes.

Operations and Maintenance: changes required to 11 v current programming errors/hugs; adapting the existing system to meet
current and upcoming technological requirements; and updating system and/or user documentation.
ID
1
2
3
4
5
6
7
8
9
10
11
Tasfc Name
U5ITS System Administrator (SA) reviews and categorizes all Requests.
If O&M. Request goes to DIG
If Streamlining, Request goes to CG

If Streamlining. CG will evaluate and approve/deny Request. CG will forward to Translator Group
for comment and DIG for implementation schedule.
If Streamlining, TG reviews Request and recommendations. DIG determines implementation
schedule
If Streamlining. CG reviews Dig and TG recommendations and submits final Recommendation to
User Community with Implementation Schedule.

If O&M Request, DIG will review, analyze and recommend hew to proceed with Request. Forward
to Translator Group (TG) for Comment.
If O&M Request, TG comments on recommendations. Forward to DIG.
If O&M Request, DIG reviews TG recommendations and approves or denies recommendations
and includes implementation schedule.
If O&M Request, CG submits final Recommendation to User Community with Implementation
Schedule.

Start
01/02'2006

01/13/2006
02/09/2006
02/22/2006

01/13/2006
02/0*2006
02/22/2006
03/07/2006

Finish
01/06/2006

02/0*2006
02/22/2006
03/07/2006

02/09/2006
02/22/2006
03/07/2006
03/13/2006

Duration
1w

4w
2w
2w

4w
2w
2w
1w

QTflfi
Jwi Fo6 Afar
•

M™
•
i

^
M
•
•

                                     Appendix B-1
                                                                                       21

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   Estimated Timeframes for Program, Guidance, & Regulatory Changes
                  and Major Enhancement  Change Requests
Program, Guidance and Regulatory: proposals requesting changes to RCRAInfo to address new or changing information needs for
the RCRA C program.

Major Enhancements: proposals requesting changes to the national data system and/or database, however, the suggested change
docs not meet the criteria to he classified as "Streamlining".
to
1
2
3
4
5
6
7
6
9
10
11
12
Task Name
USITS System Administrator (SA) reviews and categorizes all Requests
If P, G & Reg Request or Major Enhancement Request, CG will
designate the applicable Program Group (PG) and forward Request
Applicable PG will review, analyze and recommend how to proceed with
Request
TG reviews Request and PG recommendations
CG reviews PG and TG recommendations, and prepares
Recommendation for national review
National review and comment period
CG, TG and applicable PG will review any comments received
CG approves or denies Request based on feedback from national
review,
Recommendations which require Management Board (MB) approval will
be submitted to the MB
Approved Requests and Recommendations go to DIG for
implementation schedule.
Final Recommendation regarding Request distributed to User
Community by CG with proposed imptementalion schedule

Start
Q1A)2f2GQ6
01 AM/2006
01/06/2006
03/02/2006
03/1EV2006
Q4AM,'2006
05/01 £006
05/1 9/2006
05/192006
06/ORI2006
06/21/2006

Finish
01 AM/2006
01/06/2006
03/02/2006
03/15/2006
04AM/2QQ6
05/01/2006
05/1 9/2006
05/25/2006
06/08/2006
06/21, "2006
06/27/2006

Duration
0106 0206
Jan Fab Mr Apr May Jan
.6w I
E
.6w
6w
2w
3w
4w
3w
1w
3w
2w
1w

1
^^^
•
••
^H
M
•
—
•
•

                                       Appendix B-2
                                                                                            22

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                 RCRAInfo Change Management Process
                          Volunteer Response Form
                              November 14, 2005

If you would like to volunteer to be part of a Change Management Process Group, please
complete and return the following form via email to Lynn Hanifan, Region 1,
hanifan.lynn@epa.gov or Dan Bakk, Region 5, bakk.daniel@epa.gov no later than COB, Friday,
December 9, 2005.
Name:
State/Region or HQ Office:
I am volunteering to be a Member of the following RCRAInfo Change Management Process Group. I
have read and understand the Roles & Responsibilities of the Members of this Group:


	  Coordination Group

	   Program Groups (please specify the group below):

           	  Corrective Action Group

           	  Permit/Closure Group

           	  Site Identification Group

           	  Waste Activity Group

           	  Compliance/Enforcement Group



	  Translation Group
The following outlines my relevant experiences with the issues the above-noted Change
Management Group will be responsible for when implementing the CMP:
                                                                                23

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I would like to provide the following additional comments regarding my experiences with
the WIN/INFORMED process for determining the information needs of the RCRA C
Program:
                                                                            24

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