ICIS-NPDES: PCS Modernization Background Briefing for Catherine McCabe, OECA’s Deputy Assistant Administrator December 29, 2005 Attendees: DH, MS, CM and David P.

2 Outline for Today’s Briefing  National Information System Overview  ICIS Overview  ICIS Phase I – Core Federal Compliance and Enforcement Data Component  Legacy Permit Compliance System (PCS) Today  ICIS-NPDES (PCS Modernization) Status  Risks and Challenges  Subsequent Briefings

3 EPA and OECA National Information Systems Introduction  There are numerous EPA national information systems: financial/HR for internal operations and programmatic.  A national information system is defined by several key factors:  Supports a national business/ program need.  Software and hardware centrally maintained.  Data entry into system at multiple locations.  Viewing the data on screens, running queries or reports is possible at multiple locations.  Policies for use of the system: e.g., data entry, data quality, security and access, and change control.  User support, help line and training. In general, the hardware and software is located at RTP and OEI ’ s National Computer Center.  NCC maintains the hardware and some of the software  Program offices, such as OECA, maintain the software. Exceptions: OECA has moved IDEA/ECHO/OTIS to Veterans Administration, and some systems are LAN based

4 EPA and OECA National Information Systems Introduction - continued Operation of National Information Systems are subject to extensive statutory (Clinger-Cohen Act), regulatory and policy control. Capital Planning and Investment Control (CPIC) annual and periodic submittals to OEI and OMB. Agency information management policies and committees, such as QIC. Security controls by NCC, OMB, and Congress OMB, GAO and IG oversight. States: ECOS primarily.

5 EPA and OECA National Information Systems Intro - continued OC National Systems ProgramApplicable Information System Federal civil enforcement and compliance activities and outcomes ICIS Integrated Compliance Information System NPDES permitting, enforcement and compliancePCS Permit Compliance System CAA enforcement and complianceAFS Air Facility System RCRA enforcement and complianceRCRA – INFO (enforcement and compliance module only) Federal FIFRA, TSCA and TRI enforcement and compliance, and state pesticide grant activities FTTS/NCDB FIFRA/TSCA Tracking System and National Compliance Data Base Targeting, program management and public access to multi-media integrated data on enforcement and compliance plus. IDEA, OTIS and Watch List, and ECHO Integrated Data for Enforcement Analysis Online Targeting Information System Enforcement and Compliance History OnLine

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

7 ICIS Phase I: Core Federal Enforcement and Compliance Data  Launched in June  Approximately 1200 federal (EPA HQ and Regions) users.  Supports EPA federal users enforcement and compliance tracking, targeting and reporting needs.  Enables enforcement staff and managers in EPA regional offices to track activities at individual facilities (e.g., inspections, compliance determinations, and enforcement actions).  Used to manage the EPA enforcement program at both a regional and national level.  Primary tool EPA uses report its annual accomplishments to Congress and the public.  Non-enforcement sensitive data is publicly available on ECHO website.

8 Legacy PCS Today One of the Agency ’ s largest and most complex systems.  In continuous operation, maintenance and enhancement mode since  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 (FOIAs) Requests and EPA websites.

9 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 ).  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

10 ICIS-NPDES (PCS Modernization): The Need to Modernize  Legacy PCS has been FMFIA Agency Level Weakness since Modernizing PCS is key component of remedying this weakness.  Legacy PCS does not support new 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.

11 ICIS-NPDES (PCS Modernization): The Need to Modernize (continued…)  Streamlined Data Exchange with States. Will use the National Environmental Information Exchange Network,and Central Data Exchange (CDX – EPA ’ s Network node), to better exchange data with States.  Supports EPA Information Technology Initiatives. Will support data integration, EPA/State data standards, and the Agency ’ s Enterprise Architecture.  In sum, will improve EPA ’ s and States' ability to manage the NPDES program.

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

13 ICIS-NPDES (PCS Modernization): Progress To Date  NPDES Data Requirements Completed September  Developed with 6 workgroups over more than 6 months.  36 state participants from 21 states; all Regions, OW and OECA  Detailed Design (1,600 page document) Completed September  Five NPDES Design Workgroups over more than 7 months provided input:  27 state participants from 14 States, 37 regions and HQ (OW, OEI, OECA) participants  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.

14 ICIS-NPDES (PCS Modernization): Progress To Date (cont…)  ICIS-NPDES Risk Management Plan Completed March  Identified risks that could prevent completing the project on time and on budget.  Presented strategies to reduce chance risk would occur and options to mitigate impact of risk if it occurred.  Overall identified approximately 200 risks across 17 categories.  Final analysis involved analyzing the risks with the highest ratings (e.g., the most severe risks to project) and identifying the top risks that jeopardized the project.  Selected 11 State Recipients of FY2005 OECA Multi-Media State and Tribal Assistance (STAG) Grants July  23 states submitted grant proposals for PCS Modernization state activity technical assistance.  Software Development Completed September  User Preview Sessions Completed: Summer and Fall  Alpha Tests for EPA HQ Staff Completed in September and December 2005.

15 ICIS-NPDES (PCS Modernization): FY2006 Plans  Continue Data Migration (October 2003-August 2006).  Data migration is the mapping of the data elements from the old to the new system, and then the clean-up and conversion of the old data so that it can be moved to the new system.  Data Migration Plan (April 2004).  Data Migration Workgroup Formed (May 2004).  state participants (Direct and Non direct states), plus Regions and HQ.  First and second wave of states are exceeding or meeting all data cleanup metrics.  Third wave of states’ data migration and cleanup effort proceeding slowly.

16 ICIS-NPDES (PCS Modernization): FY2006 Plans (cont…)  System Fully Ready for User Acceptance Review and Approval ( December 2005).  BAH delivers fully-tested system ready for EPA and State User Acceptance Testing.  UAT (User Acceptance Testing) Training (January 2006)  Training for direct user states and regional participants. Primary participant focus for UAT training will be our current 14 first release states. Concurrent UAT training for our current federal ICIS Phase I users will also be provided, as well as potentially several independent testers hired by EPA.  User Acceptance Testing Completed ( February 2006).  Beginning January 16, 2005, testing by EPA and states (and independent testers) to ensure system meets requirements for the NPDES program as specified in the Detailed Design and that their state data has been successfully migrated.

17 ICIS-NPDES (PCS Modernization): Schedule for First Release - “Direct Users”  Live Operations for 7 Direct User NPDES States and All Federal Enforcement and Compliance Users (March 2006).  Wave 1 of the first release of ICIS 2.0 for Federal enforcement and compliance (FE&C) personnel and 7 of the initial 14 direct user NDPES states.  Region 1 (New Hampshire, Massachusetts, Rhode Island) Region 2 (New York) Region 3 (Maryland, DC) Region 5 (Indiana).  Live Operations for Remaining (7) of the Initial 14 Direct User States (June 2006).  Wave 2 of the first release of ICIS 2.0 for the remaining 7 of the initial 14 direct user states from PCS to ICIS 2.0.  Region 2 (Puerto Rico, Virgin Islands) Region 6 (New Mexico) Region 8 (Utah) Region 9 (Hawaii) Region 10 (Alaska, Idaho).  Live Operations for “all” Remaining Direct User States (August/September 2006).  Wave 3 of the first release of ICIS 2.0 for the remaining Direct User NPDES States to include Territories and Tribes (approximately 9).

18 ICIS-NPDES (PCS Modernization): Schedule for Second Release - “Indirect User States” (Batch)  Continue Work on ICIS-NPDES XML Batch Release:  ICIS-NPDES XML Schemas Development, Review and Approval.  Development of batch XML schemas were completed by BAH and EPA staff in March  OEI and Network technical review completed July  ICIS-NPDES Batch Process Independent Review.  Independent contractor review of ICIS-NPDES Batch process to start November  Review will focus on lessons learned from recent failure of Interim Data Exchange Format (IDEF) middleware and any issued identified on the current Legacy PCS batch card processing.  Review will address concerns raised by some states about batch in a June 8, 2005 ECOS Letter to OECA and OW.  Review will be coordinated with the States.  Develop Detailed Plan for Batch Release.  Originally planned for development in Spring  FY2006 funding cut means this will be delayed until FY2007.

19 Risks/Challenges of Greatest Concern  Despite best planning, all complex IT projects have known and unknown risks.  Contractor will be unable to fix one or more major defects (bug), or sum total of other defects means system not ready.  Staffing  Critical staff overworked and spread too thin. Loss of key staff or managers.  Trying to find details to supplement staffing.  Data Migration  Going well, but shared hardware environment at EPA’s National Computer Center is major risk.  Reports Capability  User Support  Administrative Process Burden

20 Risks/Challenges of Greatest Concern -- continued  In FY2006 our base budget for PCS modernization cut by $1 million. This was caused by a $6.1 million Congressional reduction to OECA’s compliance monitoring funds.  While OECA has re-allocated staff resources to support PCS modernization, the $1 million reduction in FY2006 means we will not be able to even start software development to move the remaining “batch” states to the modernized system until FY2007.  This delay in the batch release means:  Many states will be forced to continue to use PCS for a longer time, some until 2009 or beyond. These states will complain about the burden of double data entry, which the modernized ystem was designed to solve.  We had projected in our last CPIC submission to OMB that we would shut down PCS in 2008; the budget reduction is likely to require us to continue to operate PCS through 2009 or even longer.  OECA and OEI have both given out grants to states to help states prepare for the new system. The milestone schedules for these grants may no longer work given EPA’s budget reductions.  OECA, OEI and 13 states are working collaboratively to develop a national web tool for NPDES facilities to electronically report their discharge monitoring reports into modernized PCS using the National Environmental Information Exchange Network. The timing works well the recently issued CROMERR rule. The states are doing this with an OEI Network grant, but with the budget cut, EPA can no longer keep up its part of the work.  The cost of the batch release will increase as we will lose knowledgeable contractors later this year if we cannot start work on batch this FY.

21  ICIS-NPDES Policy Statement  Draft of ICIS-NPDES Policy Statement recently submitted to Expanded State/EPA Steering Committee.  First meeting of Expanded Steering Committee late January or February.  Issues likely to be controversial as states may not be willing or able to provide EPA with all the data.  Monthly ICIS Status Briefings for DAA.  We did these for former DAA. Subsequent Briefings