ICIS-NPDES: PCS Modernization Background Briefing for Granta Nakayama October 7, 2005

2 Outline for Today’s Briefing  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 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 )

4 ICIS Phase I: Core Federal Enforcement and Compliance Data  Launched in June  Approximately 1200 federal (EPA HQ and Regions) users.  Provides real time EPA data entry with desk top access.  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 to report the results of its activities to Congress and the public.  Non-enforcement sensitive data is publicly available on ECHO website.

5 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.

6 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

7 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.

8 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.

9 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...

10 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.

11 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.  Prioritized risks that were identified.  Presented risk mitigation strategies.  Provided contingency options for unmitigated risks.  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 2005.

12 ICIS-NPDES (PCS Modernization): FY2006 Plans  Continue Data Migration (October 2003-August 2006).  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.  User Preview Sessions Conducted (Summer and Fall 2005).  Presentations at upcoming national meetings of EPA groups and state associations as well as monthly sessions for users to preview various capabilities of the new system.

13 ICIS-NPDES (PCS Modernization): FY2006 Plans (cont…)  Alpha Test for EPA Headquarters Staff (September and December 2005).  Two week long alpha tests for EPA HQ staff testing of the new system.  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.

14 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).

15 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  Results of review will be used to update existing batch related risk in the March 2005 ICIS- NPDES Risk Management Plan.  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 State/EPA IDEF Project Team.  Develop Detailed Plan for Batch Release.  Originally planned for development in Spring  FY2006 funding cut means this will be delayed until FY2007.

16 Risks/Challenges of Greatest Concern  Despite best planning, all complex IT projects have known and unknown risks, but tight resources makes it difficult to resolve problems without schedule impacts.  Staffing  Critical staff overworked and spread too thin. Loss of key staff or managers.  Trying to find details to supplement staffing.  FY 2006 Funding cut delays batch release and reduces O&M budget.  Data Migration  Going well, but shared hardware environment at EPA ’ s National Computer Center is major risk.  Reports Capability  User Support  Administrative Process Burden

17  ICIS-NPDES Policy Statement  Risks/Challenges Impacting FY2006 Releases  Risks/Challenges In FY2007 and Beyond Subsequent Briefings