A Roadmap for Coordinated Tracking of Institutional Controls EPA Office of Superfund Remediation and Technology Innovation July 2003

IC Tracking Roadmap Efficacy FY02 FY05 FY04 FY03 National Coordinated Tracking Leading and Facilitating IC Data Sharing Leading and Facilitating National Scale Coordinated Tracking Building Intra-EPA IC Tracking Enterprise Building an EPA IC Tracking Prototype Developing the Policy and Culture for Coordinated Tracking

Where We Have Been – Collaborative Partnerships • Developing the Policy and Culture for Coordinated Tracking Building an EPA IC Tracking Prototype Leading and Facilitating National Scale Coordinated IC Tracking

Developing the Culture and Policy for Coordinated Tracking Final guidance on Identifying, Monitoring, Evaluating, and Selecting ICs at Superfund and RCRA Correction Action Cleanups Draft guidance on Implementing, Monitoring, and Enforcing ICs at Superfund, Brownfields, Federal Facility, UST, and RCRA Corrective Action Cleanups (addressing external comments) Draft guidance on ICs and Communities (in internal review)

Building an EPA IC Tracking Prototype Conducted Comprehensive IC Tracking Related Research • Examined IC use in Federal and State Cleanup Programs • Distributed Information Collection Request (ICR) for IC Tracking Systems/Costs to 250 organizations and summarized ICR Results • Examined the IC Tracking Business Process – IC information collection, IC information ownership, IC users, and IC information relationships • Conducted IC Data Collection Pilot in Regions 3 and 5

Building an EPA IC Tracking Prototype, (cont’d) Developed IC Light Data Collection Prototype Developed a prototype web application to test the process of entering/exchanging IC data Conducted IC Light data entry training in Region 5 and for CERCLIS HQ requirements team Produced EPA-required system documentation (Concept Paper, Requirements Document, Design and Maintenance Document, Data Element Dictionary)

Building an EPA IC Tracking Prototype, (cont’d) Developed IC Mapper Developed a prototype GIS web application to display geospatial information related to ICs Populated application with available IC coverage data for select pilot sites

Leading and Facilitating National Scale Coordinated IC Tracking Facilitated Stakeholder Focus Groups to Identify Core IC Data Collaborated with over 200 individuals (program managers, site managers, attorneys, subject matter experts, policy staff, information management/IT staff) from 92 organizations: - All EPA Regions and HQ (OSWER Info Mgmt, OERR, OBCR, OSW, OUST, FFRRO, OECA/OSRE, OGC, OEI) - Other Federal Agencies (DOD Branches, DOJ, DOE, DOI, GSA, USACE, ATSDR) - States/Tribes (25) and Local Government (12 cities/counties); - NGOs (RFF, ELI, ASTSWMO, ICMA, Environmental Council of the States (ECOS), National Tribal Environmental Council (NTEC), Center for Public Environmental Oversight (CPEO), American Land Title Association(ALTA)) - Non-Regulated Industry (Terradex, VISTA, NETRonline) Defined comprehensive list of voluntary IC data elements – identified 33 core data categories and associated data elements

Planned and Coordinated IC Tracking Pilots Leading and Facilitating National Scale Coordinated IC Tracking, (cont’d) Planned and Coordinated IC Tracking Pilots IC Tracking Pilot Agreements One Call Pilot Agreements

Crafted Common IC Tracking Language Leading and Facilitating National Scale Coordinated IC Tracking, (cont’d) Crafted Common IC Tracking Language Developed preliminary common language for exchanging data among programs (Intra-EPA, EPA ø Federal Agency, EPA ø States ø Locals) Developed Draft IC Data Element Registry Conducted training for RPMs/site managers at EPA and States Developed National IC Tracking Action Plan

Where We Are Going – The IC Network Vision Talking points on graphic. The IC network, as we envision it, will allow individual IC data owners to share a portion of their IC data with the IC network community. Such shared data will be available to other members of the network, and a portion of the shared information will be available to the general public. As the diagram shows, each member of the network would be able to collect, manage, and own their IC information. Upon the discretion of the data owners, they may share their IC data. Because varying IC data – and, in turn, IC data owners – may impact the same site or multiple sites, the network will allow government regulators as well as members of the general public to access the complete picture of IC information. We believe that each cleanup program, within Federal and State governments, will have an incentive to join the IC network when it is established. With continued emphasis on reuse-based cleanups, each cleanup program depends on the use and, in turn, the efficacy of ICs. Indeed, the Brownfields Law and our Common Elements guidance actually makes compliance with ICs a pre-requisite to the CERCLA liability protections that it provides. Thus, we believe that cleanup programs will increasingly need to record ICs in a way that makes them readily available to other government entities, the redevelopment community, and the general public.

Where We Are Going – The IC Network Vision, (cont’d) IC Tracking Network Vision As the graphic shows, coordinated tracking: Provides for linked information systems with shared data Allows for single point of access to IC information Describes what information is available and where it is located Provides the complete picture of IC information for any given area of concern Gets the right data, to the right people, at the right time

Why is Coordinated Tracking Needed? • Essential for effective revitalization and reuse of properties – fosters future redevelopment by providing a clear picture of allowable future land uses Enables consistent tracking of ICs across regulatory programs and jurisdictional boundaries since IC stewardship involves involvement of authorities from multiple government agencies and multiple IC data owners Protects human health by providing clear, accessible information to the people who may be exposed to residual contamination left in place Protects the integrity of existing engineered remedies and engineered controls

Why is Coordinated Tracking Needed? (cont’d) Potentially increases public and regulatory acceptance of IC use, thus facilitating IC use and, in turn, enabling more future use-based or redevelopment-minded cleanups Aids in selecting and implementing ICs that are effective, measurable, and protective of human health and the environment Provides capability to measure the true costs of implementing, monitoring, and enforcing ICs For EPA sites, coordinated IC tracking is consistent with EPA’s One Cleanup Program - each cleanup program should track ICs in a similar manner

The Action Plan: Three Milestones for Success 1) Construct the Intra-EPA Enterprise for Tracking and Sharing IC Information among EPA Cleanup Programs 2) Develop Guidance and Promote Culture of Coordinated IC Stewardship among EPA programs, States and Local Governments 3) Lead and Facilitate Efforts for Inter- Governmental Coordinated IC Sharing

Building Intra-EPA IC Tracking Enterprise Complete Efforts to Develop Common IC Data Elements Conduct focused data element discussions with stakeholders Conduct detailed data registry discussions (data format and length standards) Develop a final IC Tracking Registry

Building Intra-EPA IC Tracking Enterprise, (cont’d) Complete IC Light Prototype Activities Finalize IC Light System documentation (Security Plan, Risk Assessment, Test Acceptance Plan, Quality Assurance Plan, CERCLIS MOA, CIPC documentation) Expand the use of IC Light and collect feedback

Building Intra-EPA IC Tracking Enterprise, (cont’d) This is a test site in development hosted external to EPA

Building Intra-EPA IC Tracking Enterprise, (cont’d) This is a test site in development hosted external to EPA

Building Intra-EPA IC Tracking Enterprise, (cont’d) This is a test site in development hosted external to EPA

Building Intra-EPA IC Tracking Enterprise, (cont’d) This is a test site in development hosted external to EPA

Building Intra-EPA IC Tracking Enterprise, (cont’d) Develop Full IC Tracking System Migrate IC Light to a comprehensive, cohesive tracking system with GIS components that pulls/pushes information from/to existing systems co-regulators, RPs, decision makers, and the public Development Principles - Phased development (using rapid prototyping and pilots) and rollout to user community - Integrated platform that is scalable, reliable, secure, flexible, and based on open Internet standards

Building Intra-EPA IC Tracking Enterprise, (cont’d) Develop IC Tracking System Components Security and Access Control Module (Public and Secure Areas) Work Flow and Review/Approval Process to ensure appropriate data quality Report/Query Builder Mapping Tools to display ICs within a geospatial context (roads, rivers, major land features) Expert System Modules to provide tools to individuals - IC Selection/Implementation Planner - IC Assurance Planner - IC Cost Estimator

Building Intra-EPA IC Tracking Enterprise, (cont’d) Prepare IC Tracking System Life-Cycle Documentation IC Tracking System is defined as a “major EPA application” that requires: - Coordination with OSWER, Program Offices, Office of Environmental Information, CDX, Environmental Data Standards, System of Registries, National Technology Services Division (NTSD) at RTP, NC - Capital Planning and Investment Control requirements – Cost/Benefit Analysis, Acquisition Plan, Security Plan, Privacy Plan, Risk Management Plan, Records Retention Schedule, Risk Adjusted Return on Investment - EPA NTSD requirements for application to reside on EPA server

Leading and Facilitating IC Data Sharing: The Pilots Data Capture/Exchange Pilots (System ø System) Regions: 2, 3, 5, 6 and 9 States: WI, PA, NJ, NY, NV, CA Locals: City of Rochester, Kansas City Other Federal Agencies: DOE LTS Geospatial Environmental Mapping System Industry: Terradex, AGT Central Data Exchange

EPA-Industry Data Sharing Pilot

Leading and Facilitating IC Data Sharing: The Pilots, (cont’d) One Call Pilots Innovation Pilots States - WI, PA, NY

Resources Required for Contractor Support Cost of Activities Completed To Date $880k Funding Used from GSA Task Order

Resources Required for Contractor Support, (cont’d) Cost of Continuing Activities Common IC Language ($150k) Guidance/Training ($750k - 3 @ $250k each) Outreach/Conferences ($250k) Data Capture/Exchange Pilots ($500k -10 @ $50k each) One Call Pilots ($300k - 3 @ $100k each) IC Tracking System Full-Scale Implementation ($1M) IC Tracking System Components ($900k - 3 @ $300k each) System Life Cycle Documentation ($500k - ???) Total $4.4M* - A fraction of the average cost of a Superfund cleanup and potentially less than the cost to human health and the environment at one site should a significant breach of an institutional control occur. * Cost includes data collection/population activities for new sites that enter the post-construction pipeline, not historical sites.