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Meeting Data Needs of CWA NPDES Program Through a Modernized PCS

This presentation discusses the status and challenges of modernizing the Permit Compliance System (PCS) to meet the data needs of the Clean Water Act National Pollutant Discharge Elimination System (CWA NPDES) program. It covers the phases, delivery time frames, functionality, and benefits of the modernized PCS.

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Meeting Data Needs of CWA NPDES Program Through a Modernized PCS

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  1. Meeting Data Needs of CWA NPDES Program Through a Modernized PCS Michael Stahl, Director Office of Compliance Office of Enforcement and Compliance Assurance U.S. EPA February 13, 2006

  2. Purpose of Presentation • Provide a common level of understanding about status and challenges of PCS modernization

  3. Integrated Compliance Information System: Phases and Delivery Time Frames 2008+ Air Facility System (AFS) Phase III Modernized Permit Compliance System (PCS) 2006/8 Phase II Completed and Launched June 2002 Federal Enforcement Docket System Phase I 2002 Regional Tracking Systems Interface with Facility Registry System (FRS) Interface with Data Integration Tools (e.g., IDEA)

  4. 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

  5. Legacy PCS Today: Key Functionality • 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

  6. 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 areas • ICIS-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

  7. ICIS-NPDES (PCS Modernization): Where We Are... Decommission & Re-engineer 1. Concept Definition (Reconnaissance) 6. Operations & Maintenance (Admin. & Enhance) System Life Cycle 5. System Implementation (System Test, Install & Accept) 2. General Design(Requirements Analysis) 3. Detailed Design (System Specifications) 4. System Development (Technical Specifications and Programming)

  8. 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)

  9. ICIS-NPDES (PCS Modernization): States’ Role and Participation • 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 Biosolids CAFOs Pretreatment CSO/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 Reports Business Rules Screens Data Flows

  10. ICIS-NPDES (PCS Modernization): Progress to Date • 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

  11. 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)

  12. Schedule for Direct Users • 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

  13. 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 flowsto the ICIS-NPDES Batch functionality • Summer 2006 • Develop a detailed plan for the ICIS-NPDES Batch release (funding dependent)

  14. What is EPA doing to help states get ready? • 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

  15. What is EPA doing to help the states get ready? • 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

  16. 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

  17. 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

  18. 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

  19. 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

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