1. Integrated Compliance Information System (ICIS) and the Exchange Network David A. Hindin, Director Enforcement Targeting and Data Division Office of Compliance Office of Enforcement and Compliance Assurance Exchange Network National Meeting Nashville, TN, April 30, 2008

2. 2 Purpose  Review ICIS-NPDES (PCS Modernization) phased approach, with emphasis on Exchange Network Flows.  Status of Alternative Analysis for ICIS- NPDES full batch.

3. 3 ICIS Phased Approach Implemented FY 2002 Replaced 3 outdated national systems and several regional tracking systems. Integrates with FRS. Used by HQ and Regions to manage enforcement and compliance. Supports annual results public reporting, such as GPRA pounds of pollutants reduced. Modernization of the CAA Air Facility System – (AFS) AFS tracks permit compliance and enforcement data for major stationary sources. FY2008: Developing Business requirements Direct Users Implemented FY 2006 21 States 2 Tribes 9 Territories More recent program requirements CAFO Storm water CSO SSO Batch Release Part 1 Hybrid Users May 5, 2008 Implement 1 State August 2008 Implement 4 to 6 States. FY09: Implement 2 to 4 states Direct entry of all data except DMR data, which will be electronically transferred. Batch Release Part 2 NetDMR Aug 2008: “demonstrable” done per Grant. FY09: Testing and Implement Permittees electronically sign & submit DMRs. Batch Release Part 3 Full Batch Begin work FY 2009 For 22 States to electronically transfer all their data from their state system. May be revised based on Alternative Analysis National Pollutant Discharge Elimination System NPDES Phase II: PCS Modernization Federal Enforcement and Compliance Phase I Enforcement Docket Clean Air Act Stationary Sources Phase III AFS Modernization Exchange Network

4. 4 Logic of the 3 Part ICIS-NPDES Batch Approach  Part 1 for DMR hybrid states provides the basic infrastructure and functionality for batch data exchanges between state NPDES information system and ICIS-NPDES using the Exchange Network.  Part 2 for NetDMR uses Part 1 functionality and expands upon it. There are three ways a state may use NetDMR: 1. State Locally Hosts NetDMR Using the ICIS-NPDES Data Flows Via the Exchange Network. 2. State Uses U.S. EPA Hosted and Maintained NetDMR (federal instance). (Assumes state is in ICIS-NPDES and not PCS.) 3. State Adopts NetDMR to Connect Directly to State NPDES Information System. – The next presentation by Brandon Harris will provide more information on NetDMR.  Part 3 for Full Batch is designed to use functionality from Parts 1 and 2 and then builds intelligence to process all data families.

5. 5 ICIS-NPDES Batch DMR Part 1 Key Milestones  October 2006: Initiated the ICIS-NPDES (PCS Modernization) Batch Integrated Project Team (IPT), Participants include staff and managers from 26 states, 6 regions, EPA/OECA and EPA/OEI. Support the development and testing of the ICIS-NPDES DMR batch release. Conducted monthly conference calls of the IPT.  November 2007: Completed functional, integration and load testing with CDX.  March 2008: Completed User Validation (real data flowing from Illinois via CDX to ICIS-NPDES) and Acceptance Testing, and DMR Schema Approved by ICIS IPT.  April 18, 2008: ICIS-NPDES XML schema and associated documents for DMR data family approved by Exchange Network NTG.  May 5, 2008: Implementation for Hybrid Pilot State: Illinois will move from PCS to ICIS-NPDES, with batch DMR flows in operation.  August 2008: Implementation for 4 to 6 hybrid States.  Spring 2009: Implementation 2 to 4 hybrid states.

6. 6 Architecture for flowing DMR data from state systems via the Exchange Network to ICIS-NPDES

7. 7 ICIS Hybrid Batch Submission Process XML data errors ? State generates and zips XMLs XML file errors ? XML files virus free and valid? State NPDES System State Uploads to CDX manually State electronic ally submits to CDX via Node CDX sends XMLs to ICIS ICIS Batch parses XMLs ICIS Batch saves data in ICIS-NPDES ICIS Batch sets status to “Completed” and sends PDF to CDX ICIS Batch logs errors CDX logs first 100 errors and sets status to “Failed” State user views status and errors on CDX web form State node gets status and downloads errors from CDX State views batch accepted, rejected, summary reports in ICIS ICIS done parsing ? Yes No

8. 8 ICIS Hybrid Batch Submission Process  State or NetDMR generates XML file, zips it up, and submits it to CDX Manual upload using a CDX web page Automated upload using State or CDX Node (recommended)  CDX performs a virus scan of the file and validates all XMLs against the ICIS schema Infected or invaild XMLs rejected as SOAP messages and status is set to “Failed” External Batch ID is assigned for tracking purposes Clean and valid XMLs forwarded to ICIS Batch and a copy is archived  ICIS Batch receives XMLs and processes them Rejects entire XML if ICIS ID is invalid or unexpected errors occur during processing Rejects one record within an XML if ICIS ID has “read rights” only, invalid transaction, missing key data, or erroneous data Saves each record into ICIS tables if no errors Creates PDF of results when batch is processed Notifies CDX to set status to “Completed”  State Nodes retrieve status and download the PDF or results when status is “Completed” or “Failed”  CDX web page submitters view status and download the PDF or results from Transaction History page  Hybrid users log into ICIS to see ICIS Batch Accepted Transactions, Rejected Transactions with errors and Audit Report

9. 9 ICIS Batch XML Transactions  ICIS parses XML files to extract individual payloads  ICIS orders payloads within batch Based on Submission Type and Transaction Type Similar to processing order followed by PCS Transaction types vary based on data family.  Five transactions types have been designed for ICIS batch that direct how the system will accept a data submission. Three of these, for the DMR data family, have been built and will be in production in May 2008. Mass Delete  Allows the user to blank out all data for an existing record along with data or links to data associated with it. Change  Allows the user to submit specific field changes to data in ICIS. Replace  Allows the user to submit blanket changes to data in ICIS by changing fields that have a tag and blanking out fields that are missing tags (targeted replacement, not full replacement) Delete  Allows the user to blank out all data for an existing record only if it has no data associated with it. New  Allows the user to add a new record to ICIS.

10. 10 Three Transactions Types for DMRs  Mass Delete (X) Allows the user to blank out all data for an existing scheduled DMR Form. Allows the user to remove an entire unscheduled DMR Form. Records an accepted or rejected transaction for each parameter and the Auxiliary Data.  Change (C) Allows the user to submit specific changes to the DMR data in ICIS. ICIS only updates the fields specified in the XML. Records an accepted or rejected transaction for each parameter that the XML attempts to update.  Replace (D) Allows the user to submit DMR data to ICIS without considering the current state of received DMR data in ICIS. ICIS replaces all of the existing data for each of the parameters submitted in the XML. Records an accepted or rejected transaction for each parameter that the XML attempts to update.  These transaction types were developed with the participation of the Integrated Project Team and are fully explained in the ICIS-NPDES XML Schema User’s Guide, Version 1.5 – For DMR Batch, March 7, 2008.

11. 11 ICIS Hybrid Batch Audit Reports  ICIS Batch Audit Reports are available to DMR Hybrid states within the Business Objects module of the ICIS online system: Accepted Transaction Report  Provides list of transactions that were accepted Rejected Transaction Report  Provides list of transactions that were rejected with the key fields of the record and a message explaining why Transaction Summary Report Provides counts of accepted and rejected transactions by data family. Provides success rate

12. 12 ICIS Hybrid Batch Error and Warning Messages  Error Messages Whenever CDX cannot properly validate a CDX user, encounters an infected submission or finds an invalid XML file, up to 100 error messages are produced. Whenever ICIS rejects a transaction, one or many error messages are produced to identify the problem. CDX error messages are presented in SOAP messages which can be returned to a State Node or displayed on the CDX web login or ICIS upload screen ICIS error messages are presented on the Rejected Transactions Audit Report, which can be accessed through the ICIS web interface, downloaded by a State Node, or displayed on the CDX web transaction history screen.  Warning Messages Warning messages indicate that a transaction has been accepted, but there is important information that the user should know about. Warning messages are presented on the Accepted Transactions Audit Report, which can be accessed through the ICIS web interface.

13. 13 Alternative Analysis  In accordance with the Office of Management and Budget (OMB) requirements, all federal agencies must periodically conduct an Alternative Analysis of their large information systems to evaluate the benefits and costs of the current systems (the status quo) in achieving the business need, and compare this to three alternative approaches for meeting the same business need.  EPA’s Office of Enforcement and Compliance Assurance (OECA) must complete an Alternative Analysis for ICIS in FY2008. While the Alternative Analysis is focusing on the full batch release, it will include all of ICIS (such as AFS Modernization).  EPA contracted with SRA International, Inc. to conduct the Alternative Analysis.  EPA is including state input in the Alternative Analysis process. EPA believes this input could help: Improve the currently planned technical approach for completing PCS modernization via ICIS-NPDES full batch; Improve the identification and evaluation of alternative technical approaches for completing PCS Modernization for the full batch states. (In a separate process, EPA also solicited input from the direct user states on their experiences in using ICIS-NPDES.)

14. 14 First Round of State Input: January and February 2008  EPA Conducted teleconferences with ICIS Batch states to explain current design for ICIS Full Batch.  SRA conducted full day meetings in DC, Denver and Atlanta with states to solicit concerns with the current planned technical approach for and identify new approaches 20 states participated, plus Exchange Network representatives, ICIS staff, OIE Staff, and several EPA regions. States were given time to develop high level proposals on alternatives to ICIS full batch Proposals were presented to EPA and state representatives to gather feedback and refine ideas.  States submitted additional information on alternative designs via written comments 11 comments were received from 12 states.

15. 15 SRA Initial Alternatives Identification  SRA evaluated state input from round 1.  In addition to evaluating state input, SRA surveyed design patterns for architectures different from EPA or State designs  SRA looked at designs from other systems at EPA  SRS looked at systems in production at other agencies (e.g. Pension Benefits Guaranty Corporation, Corporation for Public Broadcasting)  SRA reviewed literature on system designs for similar systems available to the general public  SRA proposed 2 new alternative designs for a total of 8 discrete alternatives for consideration (1 EPA, 5 State, 2 SRA) SRA detailed all 8 alternatives and highlighted pros and cons of each After additional analysis, SRA recommended elimination of three of the eight alternatives  Results were presented to, and accepted by EPA’s ICIS Senior Review Group. This narrowed the alternatives from eight to five.

16. 16 Second Round of State Review  Eight alternatives, showing the three dropped, were shared with states on March 28 and presented in conference call on April 7.  Four states also submitted written comments.

17. 17 Summary of Alternatives Proposed Alternatives Alternative 1 - Current EPA Design (Fine Grained Transactions) Alternative 2 - Coarse Grained Transactions Alternative 3 - Full Data Warehouse Alternative 4 - Summary Data Warehouse (Eliminated) Alternative 5 - PCS Data Conversion (Eliminated) Alternative 6 - ICIS State (Eliminated) Alternative 7 - Web Service Bus Alternative 8 - Data Queue

18. 18 Next Steps  We are in the process of narrowing down the five alternatives to three. This decision is expected to be made soon.  There will be a Third Round of State input. In early May, EPA will distribute the three alternatives selected for full evaluation to the states. SRA will conduct a web conference call with states to discuss the three alternatives on May 21. States may submit written comments on the three alternatives by May 30. Results of Mississippi mapping from its system to “ICIS-WENDB” will be considered in the alternative analysis if completed by May 30.  During the summer, SRA will analyze the three alternatives and evaluate them against the Evaluation Criteria (provided to the states on February 1, 2008). During the summer, SRA may contact one or more states with specific questions on an alternative. SRA will submit a final Alternative Analysis Report to EPA in September. EPA will share this report with the states.