Meeting Data Needs of CWA NPDES Program Through a

Modernized PCS

Michael Stahl, DirectorOffice of Compliance

Office of Enforcement and Compliance AssuranceU.S. EPA

February 13, 2006

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Purpose of Presentation

Provide a common level of understanding about status and challenges of PCS modernization

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Integrated Compliance Information System: Phases and Delivery Time Frames

Air Facility System (AFS)

Interface with Facility Registry System (FRS)

Federal Enforcement Docket System

Phas

e I

Pha s

e II

Pha s

e II

I

2002

2006/8

2008+

Regional Tracking Systems

Modernized Permit Compliance System (PCS)

Completed and Launched June 2002

Interface with Data Integration Tools (e.g., IDEA)

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Legacy PCS Today One of the Agency’s largest and most complex systems

In continuous operation, maintenance and enhancement mode since 1975

Contains over 30 million records, 6 to 7 million transactions/year Supports second largest data collection effort in the Federal

government -- Discharge Monitoring Reports (DMRs) Contains data for approximately 715,000 NPDES permitted

parameters Large and diverse universe of EPA and state users (over 1,000) Used by 20+ states as primary system to manage their NPDES

programs, plus additional states use system to assist in management of the program

Data publicly available through Freedom of Information Act (FOIA) requests and EPA websites

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Supports EPA and state management of the NPDES

Program: Permit Tracking: Tracking of inventory, permit events, permit

issuance and re-issuance DMR Non-Receipt Tracking: Automatic determination of non-

receipt and completeness of Discharge Monitoring Reporting data Violation Detection: Automatic determination and resolution of

violations and manual detection of Single Event Violations per regulations Quarterly Noncompliance Report (CWA 40 CFR 123.45)

Loadings: Determining the waste load on a stream from a discharger and any additional load over their permit limit

Compliance Monitoring and Enforcement Actions: Tracking of the types and numbers of inspections (scheduled and actual) and enforcement actions taken

Legacy PCS Today: Key Functionality

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ICIS-NPDES (PCS Modernization):The Need to Modernize

Legacy PCS has been FMFIA Agency Level Weakness since 1999

Modernizing PCS is key component of remedying this weakness Legacy PCS does not support several NPDES program

areasICIS-NPDES will support the collection, and use of, data to help EPA and states manage new and evolving program areas:

Storm Water Combined Sewer Overflows (CSO) Sanitary Sewer Overflows (SSO) Concentrated Animal Feeding Operations (CAFOs) Biosolids Pretreatment Effluent Trading Policy

Legacy PCS uses old technology and is not user-friendly

ICIS-NDPES will provide secure, easier access via web-based desktop tools

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Decommission& Re-engineer

3. Detailed Design(System Specifications)

4. System Development

(Technical Specifications and

Programming)

6. Operations &Maintenance

(Admin. & Enhance)

SystemLife Cycle

5. SystemImplementation

(System Test, Install &Accept)

1. Concept Definition(Reconnaissanc

e)

2. General Design(Requirements

Analysis)

ICIS-NPDES (PCS Modernization): Where We Are...

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ICIS-NPDES (PCS Modernization): States’ Role and Participation

Gathering Requirements from Users

PCS Modernization Concept Workshops 24 state participants representing 18 states Regional and HQ participants

General Design Requirements Gathering Workshops (1998-Apr 2000)

42 state participants representing 26 states Participants from all 10 regions and HQ (OW, OECA)

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Six NPDES Data Requirements Workgroups (Oct 2001-May 2002)

36 state participants representing 21 states Participants from 10 regions and HQ (OW, OECA, OEI)

Core NPDES Program BiosolidsCAFOs PretreatmentCSO/SSO Stormwater

Five NPDES Design Workgroups (Oct 2002-Sept 2003)

27 state participants representing 14 States 37 regional and HQ (OW, OEI, OECA) participants

Background Processing ReportsBusiness Rules ScreensData Flows

ICIS-NPDES (PCS Modernization): States’ Role and Participation

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NPDES Data Requirements completed September 2002

Developed with input from data requirements workgroups Draft sent out to all states, ECOS and ASIWPCA for review

in May 2002. Detailed Design (1,600 page document) completed

September 2003 Based on input from Design Workgroups Over 888 comments received and addressed from 21

states, 7 regions and EPA HQ (OW, OECA, OEI) document review

Software Technical Specifications (16,000 pages) completed September 2004

Software Development completed September 2005

ICIS-NPDES (PCS Modernization): Progress to Date

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Schedule for Direct Users January – February 2006

User Acceptance Testing

February – March 2006 Training

March 31, 2006 Wave 1 : Live operations for 7 Direct User NPDES

states and all federal Enforcement and Compliance users

Region 1 (New Hampshire, Massachusetts, Rhode Island), Region 2 (New York), Region 3 (Maryland, DC), Region 5 (Indiana)

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June 2006 Wave 2: Live operations for the remaining 7

Direct User states Region 2 (Puerto Rico, Virgin Islands),

Region 6 (New Mexico), Region 8 (Utah), Region 9 (Hawaii), Region 10 (Alaska, Idaho)

August 2006 Wave 3: Live operations for all remaining

Direct User NPDES states to include territories and tribes

Schedule for Direct Users

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Schedule for Indirect Users (Batch)

July 2005 ICIS-NPDES Schemas have been reviewed and

approved for posting on Exchange Network website Spring 2006

NPDES Batch Transmission Independent Review to evaluate applicability of lessons learned from the IDEF, PCS flat files, and network flows to the ICIS-NPDES Batch functionality

Summer 2006 Develop a detailed plan for the ICIS-NPDES Batch

release (funding dependent)

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EPA has taken and is taking many actions to reduce the burden associated with the expanded data elements, including: Designing a new system that makes manual

data entry much easier Working to make sure that states can easily

flow data to the new system using the National Environmental Information Exchange Network

Supporting creation of electronic DMRs Draft ICIS-NPDES Policy Statement provides 3

years for states to meet new data entry requirements

What is EPA doing to help states get ready?

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Using OEI and OECA grant programs to help states prepare for ICIS-NPDES

FY2004 10 OECA grants were awarded, totaling $1.87

million 6 OEI Exchange Network grants included ICIS-

NPDES activities (totaling $1.65 million) FY2005

11 OECA grants, totaling $1.7 million 7 OEI Exchange Network grants included ICIS-

NPDES activities, totaling $2.83 million eDMR multi-state grant awarded ($750K)

FY2006 Anticipate continued support in both grant

programs

What is EPA doing to help the states get ready?

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What is the ICIS-NPDES Policy Statement?

Existing PCS Policy Statement was issued in 1985

The ICIS-NPDES Policy Statement: Establishes ICIS-NPDES as the national

database of record for the CWA NPDES program

Sets forth the data entry needs associated with ICIS-NPDES

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Why Do We Need the ICIS-NPDES Policy Statement?

ICIS-NPDES, the modernized system, will change many of the current data management practices for PCS The NPDES Program has new data needs Web interface system allows for more

decentralized data entry Ability to track and report on the entire

NPDES universe Desktop access

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What Is the Role of the Expanded Steering Committee?

Many of the items raised by ECOS in summer 2005 are under the ICIS-NPDES Policy Statement:

DMR reporting Reporting burden Electronic data exchange to ICIS-NPDES

Continuing and preserving the work done to date by the PCS Steering Committee while adding the ECOS and ASIWPCA perspectives

The Expanded Steering Committee has to address the difficult issue of resources in moving forward with the CWA NPDES program

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What Do We Need to Accomplishin 2 Days?

Enhance open lines of communication between all parties involved

Identify issues that need continued discussion to determine options for resolution

Determine a specific path/process for moving forward on those issues

Long-term… Finalize the ICIS-NPDES Policy Statement by September 2006