Feasibility Study for the
Pretreatment Permits and Enforcement
Tracking System (PPETS)
September 30, 1986
Office of Water Enforcement and Permits
U.S. Environmental Protection Agency
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FEASIBILITY STUDY OVERVIEW
The National Pretreatment Program (NPP) requires that EPA implement
nationwide regulations controlling the pollutants discharged to Publicly Owned
Treatment Works (POTWs) by Industrial Users (lUs). EPA. initiated a study td:
O^ determine the feasibility of developing a Pretreatment Permits and Enforcement"
\K Tracking System (PPETS) to assist in overseeing NPP requirements.
IV .
^ The full feasibility study is made up of; three parts:
ft\. • Summary of Pretreatment Tracking Needs ' .
• Evaluation of Alternatives for the Pretreatment Permits and
Enforcement Tracking System
• Pretreatment Permits and Enforcement Tracking System Initial
System Design.
This combined volume includes all three, feasibility study document? .plus am:
executive summary.
The Summary of Pretreatment Tracking Needs describes the specific types1 of
information that will be required by EPA Headquarters, EPA Regions, andIS
Approved States to adequately oversee pretreatment program implementation^
The report is compiled from interviews with EPA'Headquarters', Regional, and
State personnel and from existing knowledge of the National Pretreatment
Program.
The Evaluation of Alternatives for the Pretreatment Permits -arid'
Enforcement Tracking System presents five alternative automated systems to
satisfy the identified pretreatment tracking needs. The-document .analyzes
each of the proposed alternatives over a wide range of cost "arid performance
criteria and then recommends a specific.PPETS alternative be developed.
•
The Pretreatment Permits and Enforcement Tracking 'System-Initial System
Design analyzes the recommended PPETS system in greater detail. The report'-
presents a general plan for developing the proposed system and-.discusses -PPETS
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Input documents, output reports, file structures, software functions, and
proposed data elements.
As a whole, the feasibility study describes the pretreatment informational
needs of EPA Headquarters, Regions, and States and recommends a specific
automated system be developed to meet those needs. This document should serve
as a basis for further pretreatment data system design and implementation
efforts.
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TABLE OF CONTENTS
PPETS Executive Summary Part I
Summary of Pretreatment Tracking Needs Part II
Evaluation of Alternatives for the Pretreatment Permits and
Enforcement Tracking System
Part III
m
Pretreatment Permits and Enforcement Tracking System
Initial System Design
Part IV
m
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PART I: PPETS EXECUTIVE SUMMARY
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PPETS EXECUTIVE SUMMARY
Background
The objectives of the General Pretreatment Regulations (40 CFR Part 403)
are to control the discharge of pollutants to Publicly Owned Treatment Works
(POTWs) from Industrial Users (lUs) to prevent interference with POTW
operations, prevent the pass through of pollutants to POTW receiving waters,
and to prevent the contamination of sludge generated at POTWs. The General
Pretreatment Regulations require POTWs to develop and implement local
pretreatment programs and to apply and enforce National pretreatment standards
(both categorical and prohibited discharge standards) and locally developed
limitations against applicable Industrial Users.
Similar to the NPDES program, the pretreatment program will generate large
volumes of data from Industrial User self-monitoring activities, POTW
compliance monitoring, and Audits and Inspections by EPA and Approved States.
The objective of this study was to initiate development of a Pretreatment
Permits and Enforcement Tracking System (PPETS) which will enable EPA and
Approved States to oversee and ensure pretreatment program implementation.
PPETS Informational Heeds
The first step in the design of PPETS was to determine the informational
needs of.EPA and Approved States necessary for pretreatment program oversight.
The PPETS informational needs were gathered through interviews with various
EPA and State pretreatment personnel. Results of these interviews were
presented in the Summary of Pretreatment Tracking Needs. Overall, the EPA
Headquarters, EPA Region, and State personnel interviewed expressed many
informational needs, including data to support decision making in the
following areas:
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Determination of the Overall Effectiveness of the National
Pretreatment Program
Evaluation of Regional and Approval Authority Oversight
Effectiveness
Determination of POTW Compliance with Pretreatment Program
Requirements and the Overall Compliance of Industrial Users
Allocation of EPA Resources and Refinement of Existing Programs
Development of National Policy and Enforcement Strategies.
PPETS Alternatives
To satisfy the identifed pretreatment data requirements, several different
automated systems were proposed. After careful consideration, five
alternatives, meeting various levels of pretreatment needs, were chosen for
further analysis. These alternatives were designed ,to support the current and
future needs of EPA Headquarters, Regions, and delegated States. As
pretreatment programs are developed nationwide, data needs will grow from
tracking program status to tracking enforcement and effectiveness. During the
feasibility study, all five alternatives were analyzed in detail over a wide
range of evaluation criteria. The results of these analyses are contained in
the Evaluation of Alternatives for the Pretreatment Permits and Enforcement
Tracking System.
The five identified alternatives for the Pretreatment Permits and
Enforcement Tracking System (PPETS) are:
• Alternative 1: No National Automated System for Pretreatment
Permits and Enforcement Tracking
• Alternative 2: EPA Oversight System (Headquarters and Regions)
• Alternative 3: System for Approval Authorities and Higher Levels
• Alternative 4: System for Approval Authorities and Higher Levels
(with Limited IU Data)
• Alternative 5: System for Approval Authorities and Higher Levels
(with Extensive IU Data).
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These five alternatives are summarized on the chart in Exhibit 1.
Alternative 1, 'No National Automated System for Pretreatment Permits and
Enforcement Tracking,' would continue the status quo. At present, only very
limited data about the occurrences and dates of PCIs and Program Audits is
entered into PCS. EPA has issued suggested format guidances for major
pretreatment reports, but these formats are not mandatory, and the reports are
not necessarily passed from delegated State Approval Authorities to EPA. The
current system allows EPA to verify that PCIs and Audits are being performed,
but gives little or no information about actual POTW or IU compliance.
Alternative 2, the 'EPA Oversight System (Headquarters and Regions)",1
would track data contained in the Control Authority Pretreatment Performance
Summary (PPS) format suggested by EPA in the Pretreatment Comp1iance
Monitoring and Enforcement Guidance. All of the data in the PPS would be
entered by the EPA Regions into an expanded version of the Permits Compliance
System (PCS). This system would provide summary pretreatment compliance
statistics for Ills and identify the level of enforcement, compliance, and
monitoring activity undertaken by POTWs, thus providing some basis for an
overall evaluation of pretreatment program effectiveness.
Alternative 3, 'System for Approval Authorities and Higher Levels,1 would
contain all of the PPS data tracked in Alternative 2, and would also track
data from PCI and. Program Audit checklists. The data would be stored in an
expanded PCS and would be entered by the delegated State Approval Authorities
or by the responsible EPA Regions. This system would provide more detailed
information about the effectiveness of individual POTW programs and would
provide an Approval Authority evaluation of compliance status.
Alternative 4, 'System for Approval Authorities and Higher Levels (with
Limited IU Data),1 is essentially an enhancement of the previous alternative.
In addition to all the data stored by Alternative 3, Alternative 4 would also
track data for a limited number of Industrial Users. Since the total number
of lUs is very large and may overload PCS capabilities, Alternative 4 will
only track those lUs where the Approval Authority acts as Control Authority.
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The current PCS system will be modified to track Industrial User data in an
analogous manner to the way it tracks POTW discharge, reporting, and
compliance data; these capabilities would be used by those EPA Regions and
delegated States that need special automated support to manage those Ills for
which they are directly responsible. This alternative would not only provide
summary pretreatment compliance statistics for POTWs, but would also provide
detailed data about a critical subset of Industrial Users.
Alternative 5, 'System for Approval Authorities and Higher Levels (with
Extensive IU Data),1 is a comprehensive system. It would track PPS, PCI
checklist, and Program Audit checklist data, and would also be capable of
tracking detailed data for all Industrial Users. The PPS, PCI, and Audit data
would be tracked in an expanded PCS, but the IU data would be tracked in a new
system designed expressly for PPETS. Participating Approval Authorities would
still be responsible for entering data and could track as many Industrial
Users as they deem necessary. This system would provide summary data for EPA
oversight as well as detailed data for direct regulation.
Evaluation Criteria and Analyses
As part of the feasibility study, a detailed analysis was conducted for
all of the alternatives. Some of the most important criteria considered were:
• Tracking System Objectives: the ability of each alternative to
satisfy EPA's expressed data needs
• Data Availability: the accessibility of the data that will be
required for each alternative
• "Timeline Criteria: the time frames necessary for development of
each alternative
• Lifecycle Cost Criteria: the estimated costs for development
and five years of operations of each alternative
In the Summary of Pretreatment Tracking Needs, the EPA Headquarters,
Regions, and delegated States identified 14 basic objectives for the PPETS
system. the different alternatives support these objectives in varying
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degrees, as Illustrated in Exhibit 2. Alternative 1 does not fully support
any of the objectives. Alternative 2 fully supports the two most important
objectives, "To Determine the Overall Effectiveness of the National Program"
and "To Evaluate EPA Regional Oversight Effectiveness;" it also provides
partial support for ten other objectives. Alternative 3 is more complete and
fully supports nine of EPA's objectives and partially supports the rest.
Alternative 4 supplements Alternative 3 by fully supporting several more
objectives for the subset of Industrial Users being tracked. Alternative 5 is
the most comprehensive system and, with sufficient data, could fully support
all of the EPA and State tracking system objectives.
The availability of accurate and consistent data will be crucial to the
usefulness of any system. All of the alternatives are based on current and
already proposed input documents; no alternative will entail the creation of
new input documents. EPA guidances currently have recommended formats for the
Pretreatment Performance Summary, PCI checklist, and Program Audit checklist.
However, use of these specific formats is not currently mandatory. To
effectively implement any of the above alternatives, EPA and Approved States
will have to reach agreement on use of the recommended formats, including
definition of terms. At present, EPA has not issued suggested formats for
many Industrial User reports. If Alternatives 4 or 5 are chosen, then EPA may
have to standardize formats for these existing IU reports.
The overall timeline required for system development will include
allowances for preliminary studies, design and implementation, NCC approval,
and installation and training. The more complex PPETS alternatives will
require longer time periods than the simpler ones. Estimates of the total
development time for each alternative are listed in Exhibit 3.
System lifecycle costs can be broken down into two categories: development
costs and operating costs. Development costs are all the one-time costs
associated with establishing a new system and include personnel costs,
timesharing costs, travel costs, and required hardware purchases. Dollar
estimates for the general development costs of each alternative are listed in
Exhibit 3.
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TIMELINE AND COST ESTIMATES
Alternative 1:
No National
Automated
System for
Pretreatment
Enforcement
Tracking
Alternative 2:
EPA Oversight
System
(Headquarters
and Regions)
Alternative 3:
System for
Approval
Authorities
and Higher
Levels
Alternative 4:
System for
Approval
Authorities and
Higher Levels
(with Limited
IU Data)
Alternative 5:
System for
Approval
Authorities and
Higher Levels
(with Extensive
IU Data)
Estimated Development Estimated Development Estimated 5 Year
Timeline Costs Operating Costs
Currently in Existence
5 to 7 Months
8 to 13 Months
14 to 20 Months
27 to 36 Months
Currently in Existence
$55,000 to $78,000
$151,000 to $229,000
$322,000 to $459,000
$1,072,000 to $1,457,000
$67,000 (Approximate
pretreatment share of
PCS operating costs)
$366,000 to $610,000
$923,000 to $1,262,000
$1,780,000 to $2,310,000
$7,865,000 to $9,567,000
EXHIBIT 3
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Operating costs are the costs necessary to operate, maintain, and support
a computer system. These costs include data entry, equipment maintenance,
software maintenance, timesharing, and user support. Dollar estimates for the
five year operating expenses of each alternative are listed in Exhibit 3.
Recommendation
From the analyses conducted during the feasibility study, Alternative 1,
the current system, is clearly inadequate to meet EPA's pretreatment tracking
needs. Alternative 5, while potentially meeting all of EPA's needs, is far
too resource intensive to be implemented at this time. Out of the remaining
alternatives, Alternative 4 is the best choice to fully satisfy many of the
informational needs stated by EPA Headquarters, Regional, and State personnel.
It will provide summary data about industrial compliance as well as sufficient
data on the operations of an individual POTW to maintain a record of
performance. Additionally, it will provide Regions and Approved States with
the capability to track individual performance for a subset of Industrial
Users.
Instead of being implemented all at one time, Alternative 4 should be
implemented in a two step approach:
• Step 1: Implementation of the PPETS system to track PCI,
P-rogram Audit, and PPS data (Alternative 3).
• Step 2: Enhancement of the PPETS system to track the limited
amounts of Industrial User data (Alternative 4).
This incremental approach will have a pretreatment system on-line within a
shorter period of time and will not require any duplication of effort.
Although Step 1 is to be developed as a package, use and data entry to the
system should be phased in over time. As the EPA Regions and Approved States
implement and develop their pretreatment programs, usage of the PPETS system
should be increased. It is suggested that PPETS be first utilized to track
PCI and Program Audit data. Currently, much of EPA's pretreatment efforts are
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10
directed towards PCIs and Program Audits, which provide the most comprehensive
and accurate data about POTW pretreatment program implementation. Data from
Pretreatment Performance Summaries would be incorporated into PPETS as the
second phase of Step 1. After the Step 1 PPETS system is operational, the
Step 2 system should be developed. Exhibit 4 illustrates a proposed timeline
for overall PPETS development and usage.
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u
ID PRETREATMENT PROGRAM TIMELINE
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PART II: SUMMARY OF PRETREATMENT TRACKING NEEDS
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TABLE OF CONTENTS
1. INTRODUCTION
1.1 Purpose of this Report
1.2 Type of Data Generated by the Pretreatment Program
1.2.1 Data Generated by Industrial Users
1.2.2 Data Generated by Control Authorities
1.2.3 Data Generated by Approval Authorities
2. PRETREATMENT TRACKING NEEDS OF EPA HEADQUARTERS
2.1 EPA Headquarter's General Pretreatment Information
Needs
2.2 Description of Pretreatment Tracking Data Elements
2.3 Issues Related to the Development of EPA's
Pretreatment Tracking System
3. PRETREATMENT TRACKING NEEDS OF EPA REGIONS AND STATES
3.1 EPA Regions and State Information Needs
3.2 Description of Pretreatment Tracking Data Elements
3.3 Description of Current Operating Environment
3.4 Issues Related to a National Pretreatment Tracking
System
4. SUMMARY AND CONCLUSIONS
4-1 Summary
4-2 Conclusions
l-l
1-3
1-3
1-4
1-7
1-10
2-1
2-1
2-3
2-5
3-1
3-1
3-3
3-4
3-7
4-1
4-1
4-2
ATTACHMENTS
Attachment A: Potential Measurements and Associated Data Types for
EPA Headquarters Pretreatment Tracking Information
Needs
Attachment B: EPA Region and State Contacts
Attachment C: Potential Measurements for EPA Regions and states
Information Needs •
Attachment D: National Pretreatment Tracking System Activities
And Data Requirements
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1. INTRODUCTION
The objectives of the General Pretreatment Regulations (40
CFR Part 403) are to control the discharge of pollutants to
Publicly Owned Treatment Works (POTWs) from industrial users to
prevent interference with POTW operations, prevent the pass
through of pollutants to POTW receiving waters, and to prevent
the contamination of sludge generated at POTWs. These General
Pretreatment Regulations are being implemented through the
National Pretreatment Program. This program requires POTWs to
develop and implement local pretreatment programs to apply and
enforce National pretreatment -standards (both categorical and
prohibited discharge standards) and locally developed limitations
against applicable industrial users. Where POTWs are not
required to develop a local pretreatment program, NPDES States
with approved pretreatment programs or EPA are responsible for
applying and enforcing pretreatment standards against applicable
industrial users".
Since the beginning of the National Pretreatment Program, 90
percent of the POTWs required to develop local pretreatment
programs have received approval for their local programs.
Further, 22 out of the 37 States with approved NPDES permit
programs have received State pretreatment program approval.
Table 1-1 summarizes the current status of POTW pretreatment
program and State program approvals.
1-1
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TOTAL PROGRAMS REQUIRED: 1461
TABLE 1-1. NATIONAL PRETREATMENT PROGRAM STATUS SUMHARY
(As of 12/31/85)
TOTAL PROGRAMS APPROVED: 1313
Number of Number of
Programs Required Programs Approved
Number of
Programs Required
81
66
ME
HA
NH
*R1
*CT
*VT
Region I_I^
*NJ
NY
PR
Region II 1
DE
DC
*HD
PA
VA
*WV
Region W
*AL
FL
*GA
*KY
*NC
*SC
*TN
*MS
Region V
1L
IN
*MI
*MN
*OH
*WI
16
41
11
13
81
24
56
1
139
5
1
16
85
25
7
406
60
28-
37
51
121
55
54
.
"336
47
51
109
6
100
23
15
30
10
11
Statewide
Statewide
Z*
22
53
1
109
5
0
6
67
24
7
391
60
23
37
'49
117
52
53
Statewide
290
37
44
93
6
87
23
Region VI. 123
Number of
Programs Approved
113
AR
LA
NM
OK
TX
Region VI 1
*tA
KS
*HO
*NB
Region VI t I
CO
MT
NO
SD
UT
UY
Region IX
AZ
CA
*HI
NV
Region X
AK
ID
•OR
WA
27
12
4
20
60
76
19
13
44
53
26
6
3
2
13
3
121
15
100
1 .
5
fl
2
13
21
9
25
11
4
18
55
75
19
13
43
Statewide
35
19
3
2
2
9
0
121
15
100
1
5
42
2
13
21
6
*Approved State Pretreatment Program
1-2
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Through the development and implementation of local
pretreatment programs, numerous types of data are generated by
industrial users, POTWs, States, and EPA Regions. Some of these
data are critical to the effective administration and management
of the National Pretreatment Program as well as to the
determination of how effective the National Program is to
achieving its goals and the overall goals of the Clean Water Act.
Development of a National data tracking system is, therefore, a
prerequisite to an assessment of program effectiveness and
administration of the program at the National (EPA Headquarters)
1.1 PURPOSE OF THIS REPORT
Prior to the design and subsequent development of a National
pretreatment tracking system, the specific types of information
that would be reguired by EPA Headquarters, EPA Regions, and
States to adequately oversee pretreatment program implementation
have to be identified. Further, considerations of the current
pretreatment data tracking systems and capabilities of EPA
Regions and States is also needed for evaluation of any options
proposed for a National pretreatment tracking system.
The purpose of this report is to summarize the informational
needs of, and current operating environments at, EPA
Headquarters, EPA Regions, and States. The following summary was
developed utilizing existing knowledge of the National
1-3
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Pretreatment Program and information collected from EPA
Headquarters, EPA Regions, and State pretreatment personnel.
1.2 TYPE OF DATA GENERATED BY THE PRETREATMENT PROGRAM
Prior to the description of what types of pretreatment data
should be tracked nationally, a characterization of the various
types of data generated by EPA Regions, States, POTWs, and
industrial users is needed. This section summarizes the types of
data generated by the pretreatment program in an attempt to
define the universe of information upon which decisions regarding
pretreatment data/information tracking were based.
1.2'. 1 Data Generated by Industrial Users
Industrial users are responsible primarily for complying
with applicable pretreatment discharge standards and
requirements. Generally, data on compliance with these
standards is generated by industrial users and summarized in
industrial user reports. National categorical pretreatment
standards are technology-based standards set by EPA, which apply
to 26 specific industrial categories. For those industrial users
subject to National categorical pretreatment standards,
industrial user reports are required by the General Pretreatment
Regulations (40 CFR 403.12). These reports generally include
baseline monitoring reports, final compliance reports, and
periodic compliance reports. The information required in
industrial user reports are shown in Table 1-2. These industrial
1-4
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TABLE 1*2. REQUIRED INDUSTRIAL USER REPORTS
TYPE OF REPORT
Baseline Monitoring Report
For Categorical
Industrial Users
REQUIRED
FREQUENCY OF
SUBMISSION
Compliance Schedule Progress
Report (For Categorical
Industrial Users that
Submitted a Compliance
Schedule with the BMR)
Final Compliance Report
For Categorical
Industrial Users
Periodic Compliance Report For
Categorical Industrial Users
Self Monitoring Reports
For Significant
Industrial Users
Variable
Minimum
2/year
Variable,
depends
Upon
Control
Authority
Notice of Slug
Loading
Variable,
depends
Upon Event
1
REQUIRED CONTEXTS
o Name, Address
o Description of Environ-
mental Permits
o Description of
Operations (i.e., SIC Code)
o Flow Measurement
o Measurement of Pollutants
o Compliance Certification
o Compliance Schedule
(if needed)
o Compliance with Increments
of Progress
o Reeson(s) for Delays, if
Applicable
o Flow Measurement
o Measurement of Pollutants
o Compliance Certification
o Flow Measurement
o Measurement of Pollutants
o Varies depending upon
Control Authority Require-
ments. Most will require
measurement of pollutants
at end-of-pipe location.
Other information could
include RCRA waste disposal
practices, flow measurement,
etc.
o Industrial user must
immediately notify POTW of
a slug loading event
.o Depends upon modification
requested
REVIEW AND
MAINTENANCE RESPONSIBILITY
1
o Control Authority
1
o Control Authority
1
o Control Authority
1
o Control Authority
; 1
o Control Authority
1
o Control Authority
o Approval Authority
Request for Categorical
Standards Modification -
(i.e. Net/Gross, Fundamentally
Different Factors)2
1
In the absence of an approval POTW pretreatment program, the Approval Authority (delegated state or EPA Region) must
assume the Control Authority responsibilities.
2
Requests for Categorical Standards Modification should not be considered routine in terms of reports submitted by
industrial users. Only a small percentage of industrial users will apply for categorical standards modifications.
1-5
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user reports are submitted to, as well as reviewed and maintained
by, the appropriate Control Authority, which is responsible for
determining industrial user compliance with categorical
standards. In most cases, the Control Authority will be a POTW
authority with an approved local pretreatment program. In the
absence of an approved POTW pretreatment program, Control
Authority responsibility will rest with the Approval Authority,
i.e., a State with an approved pretreatment program or EPA (see
Table 1-1.).
Industrial users, whether subject to categorical standards
or not, are subject to National prohibited discharge standards
(as defined in 40 CFR 403.5(b)), as well as local discharge
limitations and self-monitoring requirements imposed by a Control
Authority. Local discharge limitations are set by the Control
Authority to prevent discharges that contain pollutants which
interfere with treatment plant unit processes, which pass through
the treatment plant and adversely affect NPDES permit compliance
and receiving water quality, and which contaminate sludge to
levels that minimize disposal options. Local discharge
limitations are normally applied in a technically based,
defensible mariner for all industrial users of a POTW system.
Industrial users subject to categorical standards may also
be subject to locally imposed self-monitoring requirements in
addition to those required by the General Pretreatment
1-6
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Regulations. These locally imposed self-monitoring requirements
would be required at the discretion of the Control Authority and
could include information such as data to determine compliance
with local limits. Other industrial users which are not subject
to categorical standards but are regulated by local pretreatment
programs, may also be required to comply with self-monitoring
requirements of the Control Authority. These other regulated
industrial users are normally considered "significant
noncategorical industrial users" the definition of which varies
among Control Authorities. Current EPA guidance entitled
'• Pretreatment Compliance Monitoring and Enforcement Guidance" has
defined a significant noncategorical industrial user in an effort
to consistently categorize these industrial users. A significant
noncategorical industrial user is defined by EPA in this guidance
as a user which discharges 25,000 gallons per day or more, or has
a reasonable potential, in the opinion of the Control Authority,
to adversely affect the POTW (i.e., interference, pass-through of
pollutants, sludge contamination, or endangerment of workers).
The specific data required in local self-monitoring reports
depends primarily upon the needs and requirements of the Control
Authority. Further, the frequency of submission of local self-
monitoring reports can vary from as often as once per week to
not at all, depending again upon the requirements established by
the respective Control Authority.
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Early EPA estimates indicated that approximately 14,000
industrial users would be subject to categorical pretreatment
standards; more recently, many sources believe that the actual
number is larger than this estimate. At this time, there is no
reliable estimate as to the number of noncategorical industrial
users who are also regulated by POTW pretreatment programs.
1.2.2 Data Generated by Control Authorities
As a result of both pretreatment program development and
implementation activities, POTWs will generate large volumes of
data. Table 1-3 presents a brief summary of the major types of
data related to Control Authority pretreatment program
development and implementation. The development of an approvable
pretreatment program by a POTW involves the submission of
information such as an industrial waste survey to identify
industrial users (both categorical and noncategorical) serviced
by the POTW and procedures to regulate the discharge from these
industrial users. The procedures involve developing an indus-
trial user monitoring (inspection and sampling) and enforcement
program. The POTW pretreatment program submission is reviewed by
the Approval Authority. Data contained in the program submission
is utilized by POTWs during program implementation. Currently,
most local pretreatment programs have been developed, and-only a
small percentage of POTWs have not submitted pretreatment program
submissions.
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TABLE 1-3. SUMMARY OF CONTROL AUTHORITY PRETREATMENT
PROGRAM ACTIVITIES AND REQUIREMENTS
Activity/Requirement
Pretreatment Program
Development/Submission
Major Components Involved
o Legal Authority
o Industrial Waste Survey
o Technical Information
(including local limits)
o Administrative Plan for
Implementation
Pretreatment Program
Implementation
o Issuance of IU Control
Mechanism
o Industrial User Monitoring
(sampling and inspection)
o Enforcement of applicable
pretreatment standards
Removal Credits Application/
Implementation (optional)
o POTW Monitoring Data
o Documentation of Consistent
Removal Rates
o Calculation of Revised Discharge
Standards
o Local Pretreatment Program
Certification
o NPDES Permit and Sludge Management
Certification
o Periodic Reports on Consistent
Removal
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The implementation of an approved pretreatment program by a
POTW primarily involves the issuance of control mechanisms (e.g.,
discharge permits) and monitoring of industrial users to
determine compliance with applicable pretreatment standards.
Further, appropriate enforcement actions would be taken when
necessary. The industrial user monitoring data generated is,
therefore, reviewed and maintained by the Control Authority. The
types and amounts of industrial user data collected varies
depending upon the needs of, and resources available to, the
Control Authority. EPA currently recommends monitoring of
categorical industrial users at least semi-annually for
compliance with applicable pretreatment standards (categorical
standards and/or local limits). In many instances, substantial
quantities of data are generated during pretreatment program
implementation. As part of their Control Authority oversight
responsibilities, many Approval Authorities have required annual
reports from Control Authorities which summarize their
pretreatment program activities, including, in some instances,
all the monitoring data generated to determine compliance of
industrial users and enforcement actions when noncompliance was
identified. .Currently the level of detail contained in each
annual report varies dramatically in accordance with respective
Approval Authority requirements. The recent EPA "Pretreatment
Compliance Monitoring and Enforcement Guidance11 contains a
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recommended annual report format for POTWs. This recommended
format requires at least the minimim amount of information which
an Approval Authority would need regarding pretreatment
activities of the Control Authority, to evaluate the
effectiveness of its pretreatment program.
Removal credit applications (40 CFR 403.7) are another
source of data generated by Control Authorities, although
submissions are discretionary. If removal credit authority is
granted to the Control Authority, specific monitoring and
reporting requirements are then required by the Approval
Authority. These monitoring and reporting requirements generally
require the Control Authority to submit data to the Approval
Authority showing continued consistent removal of pollutants for
which removal credits were granted. Currently, only about 11 of
the nearly 1,500 Control Authorities have been granted removal
credit authority.
1.2.3 Data Generated By Approval Authorities
The Approval Authority, which is responsible for oversight
of approved POTW pretreatment programs, may generate data from
three activities: pretreatment compliance inspections (PCX's),
pretreatment program audits, and review of required annual re-
ports. Table 1-4 describes the components of each of these data
sources. PCIs were established to expand the scope of municipal
NPDES inspections to include evaluation of POTW pretreatment
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TABLE 1-4. DESCRIPTION OF APPROVAL
AUTHORITY ACTIVITIES
Approval Authority
Activity
Recommended
Frequency of
Activity
Control Authority
Pretreatment Program
Components Evaluated
Pretreatment
Compliance
Inspection (PCI)
Performed
once a
Year
o Inspection and Monitoring
of Industrial Users
o Control Mechanism
(i.e., Industrial User
Permit)
o Enforcement Procedures
o Compliance Tracking
Pretreatment
Program Audit
Performed
once every
five years
or prior to
POTW NPDES
permit
reissuance
o Legal Authority
o Industrial Waste Survey
o Technical Information
(i.e., Local Limits)
o Control Mechanism
(i.e., Industrial User
Permit)
o Inspection and
Monitoring of Industrial
Users
o Enforcement Procedures
o Compliance Tracking
o Data Management and
Public Participation
o Program Resources
Annual Report
Requirements
Required
to be submitted
at least once
a year
o Currently varies among
Approval Authorities.
Some require extensive
data to be submittted
while others do not
(See Table 1-5.)
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program implementation. The PCI is intended to evaluate the
effectiveness of the Control Authority's compliance monitoring
and enforcement program. PCIs are usually performed in con-
junction with other NPDES inspections. During the course of a
PCI, specific monitoring data on industrial users is normally
collected, in addition to information regarding enforcement ac-
tions taken by the Control Authority in response to industrial
user noncompliance.
The pretreatment program audit encompasses the review of all
aspects of a Control Authority's pretreatment program. In
addition to the data collected during a PCI, additional POTW
program elements are evaluated including legal authority, origin
and application of pretreatment standards, data management, and
program resources information.
Annual reports are currently being required by many Approval
Authorities. The purpose of these annual reports is to update
information on Control Authority pretreatment programs, ensure
that these programs are being implemented properly, and to
compliment and verify information received during PCIs and
audits. However, specific requirements for annual reports vary
among Approval Authorities. Some require information regarding
all aspects of a pretreatment program, while others may only
require notification of program changes. Table 1-5 presents a
summary of current annual report requirements based upon SAIC's
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experience.
In the absence of an approved local pretreatment program,
the Approval Authority is responsible for direct oversight of
categorical industrial users. This would result in the
generation of industrial user monitoring data and collection of
industrial user self-monitoring data by the Approval Authority to
determine compliance with applicable pretreatment standards.
Appropriate enforcement actions against noncomplying industrial
users would also be performed by the Approval Authority.
Finally, Approval Authorities may perform industrial user
monitoring of industrial users which are regulated by POTWs with
approved pretreatment programs as an independent check on
industry compliance. Such industrial inspections would usually
be performed by the Approval Authority in conjunction with an
audit. Appropriate enforcement actions may also be initiated by
the Approval Authority, possibly in conjunction with the Control
Authority. As a result of this independent industrial user
monitoring, data related to industrial user compliance will also
be generated by the Approval Authority.
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TABLE 1-5. SUMMARY TABLE OF ANNUAL REPORT REQUIREMENTS
Annual Report Elements I II III IV , . • V VI VII VIII IX X
ME NV PA VA GA ICY NC TN REG IN WI REG MS CO REG REG
updated IWS (Annual) . XX X XX XXXX
Inspection and Monitoring Efforts
Summary of Previous Years Activities XX XXXX X X
Proposed Schedule for Next Year X X
Summary of POTW Monitoring Efforts
(*sludge data only) XX XXXX X*X
Compliance Status
Description of Each Major Industry X X
Notification of Substantial Changes in
Volume or Characteristics of Pollutants X
Identification of All New Pollutants X
List of Significant Non-Compliance
industries XX X XXX X x X
List of Interference/Upset/Permit
Violation incidents X X X XXX
Summary of Compliance Status XX X XXXXX
Summary of Enforcement Action XX XXXX X XX
Summary of Control Mechanism Efforts
Issuance X XX XX
Revisions to IU Limits . X
Notification Efforts
IUs Without Compliance Schedules X X
IUs with Compliance Schedules XX X
Summary of Public Participation Efforts XX X
Program Evaluation
Evaluation of Program Effectiveness X XX
Evaluation of Resources X XXX X X
Notification of Changes to Program XX X XXXX XX
Notification of Proposed Changes XX X XXXX
Reporting Frequency M un- I/ \l ^/ 2/ 2/ 21 M M M M M M M M
yr spec qtr qtr yr yr "yr yr yr qtr yr yr yr yr yr yr
. * As of March, 1986
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2. PRETREATMENT TRACKING NEEDS OF EPA HEADQUARTERS
In an effort to evaluate the types of informational needs of
EPA's Office of Water Enforcement and Permits (OWEP) which could
be supported by a National pretreatment tracking system,
interviews of various personnel within OWEP's Enforcement and
Permits Divisions were conducted. During each interview, the
specific informational needs for a pretreatment tracking system
that would be required by OWEP personnel to properly oversee
implementation of the National Pretreatment Program were
identified. A total of nine interviews were conducted involving
11 OWEP personnel; six representing the Enforcement Division and
five representing the Permits Division. The OWEP personnel
interviewed were chosen by the EPA Work Assignment Manager.
2.1 EPA HEADQUARTER'S GENERAL PRETREATMENT INFORMATION NEEDS
Based on interview responses from OWEP personnel, the general
pretreatment information needs of OWEP that would be supported by
a National tracking system were identified. Table 2-1 presents a
summary of the general pretreatment tracking needs. These
general pretreatment tracking needs are shown in descending order
of priority and summarize both OWEP Enforcement and Permits
Division's responses. The rankings of information needs in Table
2-1 were based upon the relative level of priority chosen for
each information need by each person interviewed. Each level of
priority chosen (i.e., high, medium, low, or no) was assigned a
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TABLE 2-1. PRETREATMENT TRACKING SYSTEM PRIORITY
INFORMATION NEEDS FOR EPA HEADQUARTERS*
OWEP - ENFORCEMENT AND PERMITS DIVISIONS
1. Determine Overall Effectiveness of National Program
2. Evaluate EPA Regional Oversight Effectiveness
2. Evaluate Local Program Effectiveness
2. Determine Industrial User Compliance with Categorical
Standards
3. Evaluate State Program Effectiveness
4. Determine Industrial User Compliance with Local Limits
5. Develop Enforcement Strategies
6. Determine Industrial User Compliance With Self-Monitoring
Requirements
7. Evaluate/Refine Existing Programs
8. Allocate EPA Resources
9. Make National Policy Decisions
10. Develop National Guidance for Pretreatment Program Activities
*Trackingneeds are presented in order of importance based upon
EPA Headquarters interview responses. Some rankings may contain
multiple information needs which should be considered equal in
priority.
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corresponding numerical value (i.e., 3-high, 2-medium, 1-low, o-
no) to produce average priorities for each general information
need, which were then ranked accordingly.
The highest priority for both the Enforcement and Permits
Divisions was to determine the overall effectiveness of the
National Pretreatment Program. Other information needs that
appear as overall high priorities for OWEP are evaluating EPA
Region, State and local program effectiveness, and determining
industrial user compliance with applicable categorical
standards/requirements and local limits.
Another information need that was of interest to OWEP
personnel is the need to collect/integrate data from other EPA
programs, particularly RCRA and sludge programs. It was
generally felt however, that the need for information from other
programs is secondary, and current OWEP efforts should be first
directed towards the development of a pretreatment tracking
system which will assist OWEP in the oversight of the National
Pretreatment Program.
2.2 DESCRIPTION OF PRETREATMENT TRACKING DATA ELEMENTS
Bases on the general information needs of OWEP described in
the previous section and in Table 2-1, an effort was made to
identify the specific types of data that would need to be
included in a National pretreatment tracking system. Attachment
A summarizes, for each priority pretreatment tracking need identified
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to support the need, the data types associated with each
measurement, and for reference, the priority rankings from Table
2-1. The potential measurements and associated data types were
developed based upon the interview responses from the OWEP
personnel. The potential measurements for each pretreatment
tracking need shown in Attachment A are shown in descending order
of importance. Ideally, all measurements and associated data
types would be tracked to support the pretreatment information
need. However, due to resource or other constraints, only the
measurements and data types of higher importance may be
considered for a given need.
As shown in Attachment A, the measurements and associated
data types vary between tracking system needs. However, some
overlap of measurements and associated data types also does occur
between tracking system needs. For example, summarizing POTW PCI
results would help support a number of EPA Headquarters tracking
system needs including:
• Determining the overall effectiveness of the National
Pretreatment Program
• Evaluating local (POTW) program effectiveness
• Developing enforcement strategies
• Evaluating/refining existing programs
• Developing National guidance.
The first page of Attachment A presents a summary showing the
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measurements associated with each tracking system need. Review
of this chart reveals that several tracking system needs can be
supported through the utilization of a few potential
measurements, or types of information, common to each need.
However, it is important to note that the complexity within a
given measurement and associated data type will vary depending
upon the level (i.e., EPA Region, State, POTW or industrial user)
at which data will be tracked for each measurement. Although a
few measurements may support several tracking system needs, the
data types and level of detail desired for the few measurements
may result in a large, complex tracking system. Therefore, it is
important that the associated data types and level of detail of
data collected be considered when potential measurements are
selected.
2.3 ISSUES RELATED TO THE DEVELOPMENT OF EPA'S PRETREATMENT
TRACKING SYSTEM
During the interviews of OWEP personnel, issues related to
the development and implementation of a pretreatment tracking
system were discussed. This section will briefly summarize the
responses from OWEP personnel interviews on these issues.
Overall, it was felt that the types of data that would be
obtained for the pretreatment tracking system should be
consistent nationally and submitted in summary form. For
example, Regions, States and POTWs would all need to report
industrial user compliance by industry category. There is
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generally not a need for detailed raw data at the National level.
The consensus of opinion of the OWEP personnel was that EPA
Headquarters should require a uniform type of summary information
from EPA Regions and/or States to provide the data necessary to
support the needs of a nationwide pretreatment tracking system.
Further, EPA Regions and/or States should also be able to supply,
and the tracking system should be flexible enough to incorporate,
future pretreatment information needs.
Another issue discussed during the interview of EPA
Headquarters personnel was the type of system (i.e., manual vs.
computerized) needed to maintain the National pretreatment
tracking system. The majority of personnel felt that a
computerized-type of system would be desirable over a manual-type
of tracking system at the EPA Headquarters level. However, there
was no strong opinion as to whether the information contained in
summary reports should be submitted via computer, similar to the
PCS system, or^manually via periodic reports, by EPA Regions or
States to EPA Headquarters.
There are several issues regarding the quality of data that
will be maintained in the pretreatment tracking system. First, it
was generally felt that some level of data quality control was
needed to ensure consistency within the system. However, the
data in the tracking system would need not be of the quality so
as to support direct enforcement against noncomplying States,
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POTWs, or industrial users. The tracking system would primarily
be utilized to identify areas where follow-up actions (i.e.,
sampling, inspections, audits) were necessary. Further, it was
felt that confidentiality was not a concern regarding the data
maintained in a pretreatment tracking system. The use of the
system and data contained in it would not need to be restricted
to the parties supplying data to the system (i.e., EPA Regions
and States). In fact, most OWEP personnel interviewed suggested
that the exchange of data contained in the tracking system
between EPA Regions and States could be of use during
pretreatment program implementation.
The second issue regarding data quality is the timeliness of
data maintained on the tracking system. Needs varied among EPA
Headquarters personnel as to how current the data in the tracking
system should be. Some felt that to be of use for continual
oversight of the pretreatment program, frequent updates (i.e.,
monthly or quarterly) were necessary. Alternatively, several
people felt that too frequent an update of the tracking system
would be burdensome on EPA Regions and/or States, and the annual
or semi-annual updates would suffice.
In terms of resources, the overall opinion was that costs
related to the development of a National tracking system be kept
low. Most personnel felt that the tracking system was important
enough to develop, but given already limited resources to oversee
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the National pretreatment program, the expenditure of significant
resources for the system may not be available at the present.
Based also upon the resources currently available to OWEP, it
was felt that from one-half to one man years worth of current
effort was a reasonable cost for maintenance of a tracking system
at EPA Headquarters.
The remaining issues discussed with OWEP include system
response and compatibility with other systems. As for system
response, the majority of personnel found it sufficient to have
response to a system request in at least 24-hours. However, some
personnel would sacrifice data volume for quick-response access
(i.e., terminal access) to data maintained in the system. As for
system compatibility, the majority of personnel felt that the
pretreatment tracking system should be compatible with existing
EPA data bases. In particular, it was felt that compatibility
with the OWEP PCS system was most important because of the data
on POTWs already maintained in PCS. Compatibility with other EPA
data management systems (i.e., the Industrial Facilities Data
Base and Grants Information Control System) was felt to be not as
important at the present.
Based upon interview responses, it appears that a simple
computerized tracking system would be adequate for OWEP purposes.
In summary, this is based on the following factors:
• Data in summary form would be adequate for the system,
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opposed to detailed raw data
• Computerization of the system is desired
Headquarters over a manually maintained system
for
EPA
• Checks on data quality are needed to ensure consistency and
validity, however, the would never be directly used as the
sole basis of enforcement actions against Control
Authorities or industrial users
• Access to data maintained in the system does not have to be
restricted from or between EPA Regions and States
• Updates of the system can occur on a semi-annual or annual
basis (although several people would prefer quarterly
updates)
• Low cost system development and maintenance is desired
• Quick response access (i.e., less than 24-hour) is not
necessarily needed.
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3. PRETREATMENT TRACKING NEEDS OF EPA REGIONS AND STATES
A National pretreatment tracking system will serve a variety
of needs at EPA Headquarters. However, such a system will be
primarily supported by data and information collected by EPA
Regions and delegated States. In an effort to determine how the
tracking system could serve EPA Regions and States, consideration
of pretreatment tracking system- needs and the current operating
environment at EPA Regions and States were reviewed. This
section will summarize those needs and current environments for
EPA Regions and States, as well as discuss issues related to the
development and maintenance of a National pretreatment tracking
system. Information from EPA Regions and States was compiled
.from knowledge of Regional and State pretreatment programs and
from telephone inquiries to selected Region and State
pretreatment program contacts. Those EPA Region and State
contacts, selected by OWEP Enforcement Division personnel, are
presented in Attachment B. Those interviewed were selected
because of knowledge of the pretreatment program and not
necessarily a knowledge of EPA data systems.
3.1 EPA REGIONS AND STATE INFORMATION NEEDS
Due to the fact that EPA Regions and States each implement
their respective pretreatment programs differently, an overall
consensus of all priority pretreatment information needs could
not be identified. However., there were two general information
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needs which were common to all Regions and States:
• Determining POTW compliance with pretreatment program
implementation requirements
• Determining industrial user compliance with applicable
pretreatment standards and requirements.
The need for determining industrial user compliance varied among
those contacted. For instance, some Regions and States only
wished to consider tracking specific compliance information for
those industrial users for which they are the Control Authority
(i.e., in the absence of an approved POTW program).
Alternatively, other Regions and states felt it was necessary to
track the compliance of all industrial users within the Region or
State including those industrial users regulated by an approved
POTW pretreatment program and industrial users for which the
Region or State are the Control Authority. Further, in terms of
industrial user compliance, most Regions and States emphasized
determining compliance with only categorical standards and
requirements as opposed to categorical and local discharge
standards and requirements.
The general information needs of EPA Regions and States that
would be supported by a National pretreatment tracking system
vary s-lightly from those needs of EPA Headquarters. Specifically
the needs of Regions and States are focused primarily to
determining- POTW and industrial user compliance within their
Region and State. Additional information contained in a tracking
system (i.e., information from other Regions and States) would
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not be utilized in the day-to-day oversight of POTWs and
industrial users.
The only other information need that was suggested by EPA
Regions was that of determining State pretreatment program
effectiveness in oversight of Control Authority pretreatment
programs, and industrial users in the absence of approved Control
Authority programs. However, due to the status of state program
delegation across the EPA Regions (i.e., EPA Region VI has no
approved State programs), not all EPA Regions would need a
tracking system to support this need.
3.2 DESCRIPTION OF PRETREATMENT TRACKING DATA ELEMENTS
Based upon the general information needs identified by EPA
Regions and States, an attempt was made to describe the potential
measurements that would be required to support the tracking
system needs of EPA Regions and States. Appendix C presents a
summary of the potential measurements that would be associated
with each tracking system need.
The specific data elements within each potential
measurement, needed to support the information needs of EPA
Regions and States (i.e., determining POTW compliance with
implementation ' requirements, determining industrial user
compliance with applicable pretreatment standards and
requirements, and determining State pretreatment program
effectiveness) also varied among those Regions and States
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contacted. Generally, however, most Regions and States felt it
necessary to track data generated as a result of their oversight
activities. This includes data contained in POTW annual reports,
data generated during POTW audits and PCIs, data contained in
industrial user self-monitoring reports, and data generated
during industrial user inspections and sampling. Again specific
data elements for each oversight activity that should be tracked
did vary among each Region and State. For example, North
Carolina, New Jersey, Mississippi, and EPA Region IX felt that it
was necessary to track compliance on each industrial user in
their State or Region. Alternatively, EPA Regions,III, V and VI
feel it is only necessary to track summary information by POTW
regarding industrial user compliance. Another example of the
diversity of data elements required by Regions and States to
support essentially the same information need is POTW reporting
requirements. As described in Section 1.2.3 and Table 1-5 of
this report, these reporting requirements vary in terms of types
of data submitted, the level of detail of data submitted, and the
frequency with which these POTW reports are required. fFor
instance, North Carolina requires the submission of semi-annual
reports which"must include, in addition to other data, compliance
data on all -industrial users regulated by a POTW, EPA Region IX
on the other hand requires annual reports from POTWs which must
include, in addition to other data, compliance data on all
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industrial users regulated by a POTW, as well as quarterly status
reports from POTWs which had identified noncomplying industrial
users in their annual report.
3.3 DESCRIPTION OF CURRENT OPERATING ENVIRONMENT
Based upon telephone inquiries of the selected Regions and
States and existing knowledge, information regarding the current
pretreatment data operating environment is summarized in Table 3-
1. It is important to note that the information presented in
Table 3-1 only summarizes information on some Region and States
and thus may not represent all Regions and States involved in
pretreatment program implementation and oversight.
As shown in Table 3-1, Regions currently manage the bulk of
pretreatment program data manually, although several do utilize
some type of computer system to track limited pretreatment data
(i.e., Regions II, V, VII and X). Also, some Regions have
already begun development of a pretreatment tracking system,
primarily on personal computers, that will support their current
needs of POTW and industrial user oversight. Many States have
already developed, and are currently maintaining, computerized
data management systems for data generated from implementation of
their pretreatment programs. State computer data management
systems for pretreatment are normally maintained as a component
of an existing computer data system (i.e., PCS, STORET, State
mainframes). Further, both Regions and States as a whole appear
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TABLE 3-1. SUMMARY OF EPA REGIONS AND STATES CURRENT PRETREATHENT DATA MANAGEMENT SYSTEMS
(As of 12/31/85)
Current Type of Pretre'atment
State
Connecticut
New York
New Jersey
North Carolina
Ohio
California
South Carolina
Illinois
Indiana
Mississippi
Region
I
II
III
V
VI
vn
via
IX
X
Data Management System
Manual
Manual/Computerized
Computerized
Computerized
Computerized
Manua I /Computer i zed
Manual
Computerized
Computerized
Computerized
Manua I /Computer i zed
Computerized
Manua t /Computer i zed
Manua I /Computer i zed
Manua I / Computer i zed
Manual
'Manual/Computerized
. . Manual
Manua I/Computer i zed
Comment
State operated pretreatment program
Use PCS to track POTU program audits and inspections
Use PCS for tracking permit status of tUs outside of approved POTW.
programs. Also maintain data management system on State mainframe
to track data generated by lUs and POTWs
Use an EPA tracking system to track data generated by both IDs
and POTWs
Use State mainframe to track IU data
Use spread sheet to track general audit activity. Considering
expansion of State system to incorporate pretreatment data.
Track data by POTU only
Currently utilize a system similar to PCS on the State mainframe.
Currentty:in the process of converting over to PCS system entirely.
Use PCS to track POTU program audits and inspections
Use computer system to track IU compliance
Use PCS to track POTU program audits and inspections
Use IBM PC to track general POTU data and categorical IU compliance
data. Also use PCS to track POTU program audits and inspections.
Use PCS to track POTU program audits and inspections
Use word processing - type system to track general POTW data
Currently developing system for a PC to track POTU and IU data
Use PCS to track POTU annual report activities. Currently planning
development of system for IBM PC to track POTU data
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to utilize PCS to at least track POTW audit and inspection
activities. This may be a result of recent EPA Headquarters
policy regarding the use of PCS this year by Regions and
delegated States.
Because most EPA Regions and delegated States have
essentially just begun pretreatment program oversight activities,
estimates of workloads and resources associated with pretreatment
program data management were not readily available. The
workloads at a given Region or State will partially be dependent
upon the level at which they are involved in pretreatment program
oversight. Again, for those Regions and States that desire -to
track industrial user compliance at the industrial user level,
more resources would be required as opposed to a Region or State
that desires to track industrial user compliance at the POTW
level. Other oversight activitites by Regions and States such as
POTW audits, PCIs, industrial inspections, and annual report
requirements, will also affect workloads associated with tracking
data generated from these activities. For example, if a Region
or State desired to track specific results of a POTW audit or
PCI, the associated workloads would be greater than that required
to merely track whether or not a POTW audit or PCI was performed.
Finally, the workloads associated with pretreatment data
management will depend upon the number of POTWs and industrial
users within a given EPA Region or delegated State. For example,
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as shown in Table 1-1, EPA Region X is responsible for direct
oversight of 24 POTW pretreatment programs and one State
pretreatment program (Oregon). Alternatively, EPA Region VI has
no delegated States and is responsible for direct oversight of
123 POTW pretreatment programs.
As with workloads, the resources associated with
pretreatment program data tracking will partially depend upon the
complexity of Region or State oversight. Three states (North
Carolina, Ohio, and New Jersey) that have been utilizing
pretreatment data systems for some period of time have estimated
that approximately 1-2 man-years worth of effort in each State is
spent on maintenance of their systems. It should be noted that
these States do track data at. the industrial user level and would
expand existing systems if the capability existed.
3.4 ISSUES RELATED TO A NATIONAL PRETREATMENT TRACKING SYSTEM
During the telephone inquiries of the selected EPA Regions
and States, issues related to the development and implementation
of a National pretreatment tracking system were discussed.
Following is a brief summary of the responses from Regions and
States on these issues.
Generally it was felt that a National pretreatment tracking
system was heeded. However, most Regions and States did not feel
that it should be mandatory to supply data to a National tracking
system, especially if the tracking system could not serve their
3-8
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needs. This was especially true for Regions and States that did
not want to duplicate current pretreatment tracking efforts just
for a National system. Alternatively, Regions and States that
are just beginning to develop and implement oversight activities
felt that if the tracking system requirements were developed soon
enough, they could be incorporated into their current tracking
system development activities. If the National system
requirements were not developed in the near future, however, then
they would be less receptive to changing existing systems to
conform with the National system.
As described throughout this chapter, the types of data that
would be required in a National tracking system to support the
information needs at EPA Regions and States vary among each
Region and State. Some felt that if a National system was
developed, only summary type data should be tracked. Others felt
that a National pretreatment tracking system should have the
ability to track data at the industrial user level.
An issue that appeared to be of concern, especially for EPA
Regions, was that of consistency of data that would be tracked
Nationally. In particular, definitions for "noncompliance" and
"significant industrial user" would first have to be provided to
ensure consistency of the data tracked. Several Regions (EPA
Regions VI and IX) have already found consistency to be a problem
in POTW reporting requirements, and have prepared guidance for
3-9
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POTWs on definitions for noncompliance and significant industrial
user. EPA's "Pretreatment Compliance Monitoring and Enforcement
Guidance11, recently issued by OWEP's Enforcement Division, will
assist in clarifying these and other definitions that will be
necessary to ensure the consistency of data collected for the
National system.
Other issues directly related to the development of a
pretreatment tracking system include timeliness of data, system
access, compatibility with other systems, and system flexibility.
Although opinions varied, it was generally felt that if a
National pretreatment tracking system was going to assist Regions
and States, system updates would have to occur more than once a
year. Quarterly updates of the system would probably fulfill
many of the Regions and States needs. In terms of system access,
all Regions and States felt it necessary to have the National
pretreatment tracking system be user friendly so that access
would not be restricted to only those responsible for maintenance
of the system. Further, most Regions and States felt that system
access need not be restricted from or between EPA Regions and
States. Regions and States felt that terminal access to the
system, opposed to batch job requests, would be desirable and
sometimes necessary to adequately oversee local pretreatment
program activities. For those Regions and States that currently
maintain pretreatment data tracking systems, compatibility with
3-10
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their current system was desired so as to avoid duplication of
efforts. Utilization of the OWEP PCS system for the National
pretreatment tracking system was thought to be too restrictive as
it is currently designed. The primary reason for this was that
to obtain outputs from PCS required the use of personnel familiar
with PCS operations. Another concern regarding the PCS system as
currently designed is that State operated pretreatment programs
(40 CFR 403.10(e) States) cannot track industrial inspections for
which they have commitments to perform. The current PCS system
currently only tracks POTW oversight activities (i.e., PCIs and
Audits). Alternatively, a PCS-type system for some Regions and
States was desirable because of the greater data storage
capabilities which were not available for some States (i.e.,
North Carolina and New Jersey). Finally it was felt that if
support of a National pretreatment tracking system would be
required, then the system should have the flexibility to meet the
specific needs of the Regions and States providing the support.
Based upon interview responses, it appears that a more
complex pretreatment tracking system would be required by Regions
and States, in relation to the one required by EPA Headquarters.
In summary, this is based on the following:
• Assuming the tracking system would support Regions and
States needs, then data would need to be tracked at the
industrial user level
• At least quarterly updates of the system would be needed
3-11
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o Data contained in the system would not need to be kept
confidential, thus the system would not need to be
restricted from or between EPA Regions and States
o Immediate or on-line access would be desirable
e Compatibility with existing Region and State tracking
systems would be desired
o The system should be flexible enough to meet the needs of
all Regions and States.
3-12
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4. SUMMARY AND CONCLUSIONS
4.1 SUMMARY
The activities at all levels of pretreatment program
implementation require various types of information to support
them. Based upon the information presented in Chapters 1, 2, and
3 of this report, Attachment D presents an overview of the
activities and information needed for pretreatment program
implementation.
Figure D-l in Appendix D provides an overview of the
activities and information requirements that a pretreatment
tracking system may need to support, for all levels involved in
pretreatment program implementation and oversight (i.e., Control
Authority, Approval Authority, EPA Regions, and EPA
Headquarters). For each level of authority presented in Figure
D-l, the primary activities and associated data or information
requirements for each activity are shown. Further, Figure D-l
generally shows how the information will flow between the various
levels of authority. It is important to note in regard to Figure
D-l, that an EPA Region office can, and many currently do, have
responsibilities both at the Approval Authority level and at the
Regional level. Therefore, the activities and associated
information contained at both levels may be combined for a given
EPA Region in the absence of delegated State programs.
4-1
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Figures D-2, D-3, D-4, and D-5 in Appendix D provide a more
detailed view of Control Authority, Approval Authority, EPA
Regions, and EPA Headquarters activities and information
requirements. Specifically, Figures D-2 through D-5 provide the
general and specific pretreatment activities that are undertaken
at each level of authority, and present for each activity, the
primary data that would be needed to support the activity.
Further, the data outputs associated with each activity are
shown. The activities and associated data inputs and outputs
shown in Figures D-2 through D-5, will provide a basis for
further evaluation of how a national tracking system can support
each level of authority.
4.2 CONCLUSIONS
Overall, the development of a National pretreatment tracking
system is thought to be needed by EPA Headquarters, EPA Regions
and States. However, the information needs from a National
f
system vary slightly between EPA Headquarters and EPA Regions and
States. This variation is inherent in the responsibilities of
each in terms of pretreatment program oversight and
implementation. In general, EPA Headquarters information needs
are related more towards the overall assessment of pretreatment
program effectiveness. The needs of EPA Regions and States are
more focused on the evaluation of POTW and industrial user
compliance with pretreatement program standards and requirements.
4-2
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Due to these basic differences in information needs, the
complexity of the National tracking system will depend upon which
general needs will be met by the system. A simple tracking
system, in terms of overall size, would probably suffice for EPA
Headquarters .needs, as well as some Regions and States. This is
because only summary data regarding Region, State, POTW, and
industrial user activities would be required to support EPA
Headquarters needs. Further, as shown in Attachment A, several
potential measurements and associated data types could support
several different tracking system information needs.
Alternatively, a fairly complex system would be required to
support the information needs of several EPA Regions and States.
This would be due to the fact that some Regions and States have
found it beneficial to track data at the industrial user level.
The complexity of a pretreatment tracking system will also
depend upon the resources available for its development and
maintenance. If resources are limited only a simple system that
may only support needs for summary information may be developed.
Alternatively, a fairly complex system could be developed that
would support more detailed needs of Regions and States, but
extensive resources would be required. Finally the resources to
maintain a tracking system could also restrict the development of
the system. This is particularly true for States, which, based
on the telephone inquiries, would be against the expenditure of
4-3
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additional resources to support a system that would not be of
service to them.
Currently, both EPA Headquarters and many EPA Regions and
States maintain some type of pretreatment data tracking system.
The Permits Division at EPA Headquarters maintains some general
and biographical information regarding POTW pretreatment programs
on a personal computer. OWEP Enforcement Division tracks POTW
pretreatment program audit and inspection activities on PCS.
Several States have fairly complex systems that track
pretreatment data at the industrial user level. The primary
deficiencies of existing tracking systems utilized by Regions and
States are lack of flexibility to expand and data storage
restrictions. Other States and Regions are in the process of
developing their own tracking systems, primarily on personal
computers, to meet their own needs. PCS is now utilized by most
Regions and States to at least track POTW pretreatment program
audits and inspections.
There are many issues related to the development and
maintenance of a centralized pretreatment tracking system.
Opinions varied among all those contacted for input for this
report. Following are brief summaries of these issues.
• System Updates: EPA Regions and States believe that the
system would need" to be updated frequently (i.e.,
quarterly or semiannually) to support their needs. EPA
Headquarters may not need system updates as frequently
(i.e., possibly semiannual or annual).
4-4
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• Data Forms: EPA Headquarters needs primarily would only
require data in summary form. Most EPA Regions and States
needs would require data in a more detailed form, in some
instances at the industrial user level.
• Data Quality; EPA Headquarters, EPA Regions, and States
expresses concerns over consistency and validity of data
tracked in the system. This may be more important for EPA
Regions and States which may utilize data in the tracking
system to pursue enforcement actions against POTWs or
industrial users
• System Access; EPA Headquarters, EPA Regions, and States
currently do not feel the need to restrict access from or
between each other.
• System Response Time; In general, EPA Headquarters did
not feel that quick response time (i.e., less than 24-
hour s) is needed. EPA Regions and States generally felt
that quick access or response from the tracking system
would be needed.
• System Cost; EPA Headquarters, and EPA Regions and States
desired low cost development and maintenance. EPA Regions
and States are particularly concerned about the
maintenance cost to them if the system does not provide
them a service as well.
Ideally, the National pretreatment tracking system could be
designed so the needs of EPA Headquarters, EPA Regions, states,
and even possibly POTWs, could be met. Realistically, due to the
complexity of the pretreatment program and the inconsistency on
how the program currently is implemented, design of such a system
may be difficult at this time. Several alternatives for a
National pretreatment tracking system however, do exist that
could to be pursued at this time. These alternatives will be
described and evaluated in later sections of the Pretreatment
Tracking System Feasibility Study.
4-5
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ATTACHMENT A
POTENTIAL MEASUREMENTS AND ASSOCIATED DATA TYPES
FOR EPA HEADQUARTERS PRETREATMENT TRACKING INFORMATION NEEDS
-------
SUMMARY OF POTENTIAL MEASUREMENTS FOR EPA HEADQUARTERS
PRETREATMENT TRACKING SYSTEM NEEDS
EPA 1.DETERMINE 2. EVALUATE 2. EVALUATE 2. DETERMINE 3. EVALUATE
HEADQUARTERS OVERALL EPA REGIONAL LOCAL (POTU) INDUSTRIAL STATE
TRACKING EFFECTIVE-" OVERSIGHT PROGRAM USER PROGRAM
SYSTEM NESS OF THE EFFECTIVE- EFFECTIVE- COMPLIANCE EFFECTIVE-
NEEDS* NATIONAL NESS NESS WITH NESS
PRETREATMENT CATEGORICAL
PROGRAM STANDARDS
4. DETERMINE 5, DEVELOP
INDUSTRIAL ENFORCEMENT
USER STRATEGIES
COMPLIANCE
WITH LOCAL
LIMITS
6. DETERMIN
INDUSTRIAL
USER
COMPLIANCE
WITH SELF-
MONITORING
REQUIREMENT
POTENTIAL
MEASUREMENTS
POTU BIOGRAPHICAL DATA X
INDUSTRIAL USER
COMPLIANCE DATA XX X X X X
POTW PRETREATMENT
COMPLIANCE INSPECTION
(PCI) RESULTS X X
POTW PRETREATMENT
PROGRAM AUDIT RESULTS X X
IMPROVEMENT OF
LOCAL CONDITIONS X
OVERSIGHT ACTIVITIES
OF POTW PRETREATMENT
PROGRAMS X X
DELEGATED STATE
PRETREATMENT PROGRAM
AUDIT ACTIVITIES X
CONTROL AUTHORITY
IMPLEMENTATION BY THE
APPROVAL AUTHORITY " X X
POTW ANNUAL
REPORT RESULTS X
STATE PRETREATMENT
PROGRAM AUDIT RESULTS X
UNIQUE POTW DATA
"In Order of Relative Importance for OWEP - Enforcement and Permits Division
-------
Tracking System Objective:
Priority Ranking: 1
Determine Overall Effectiveness
National Program
of
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. POTW Biographical Data
- POTW Name
- POTW Address
- NPDES Permit Number
- Total POTW Flow
- Percent Industrial Flow
- bate Program Submitted
- Date Program Approved
- Number of Categorical Industries by Category
- Number of Significant Noncategorical Industries
- Removal Credit Application Date
- Removal Credit Approval Date
2. Industrial User Compliance Data
- Number of lUs Subject to Categorical Standards (By
Category)
- Number/Percent of lUs in Compliance With Categorical
Standards (By Category)
- Number/Percent of lUs in Compliance with Categorical
Standard Self-Monitoring and Reporting Requirements
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent of lUs in Compliance With All Applicable
Standards -
- Number/Percent of lUs Demonstrating Significant Noncompliance
3. POTW Pretreatment Compliance Inspection (PCI) Results
- PCI Date
- Number of Categorical lUs
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of lUs Demonstrating Significant Noncompliance
- Type of Enforcement Follow-up Taken By Approval Authority
A-2
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POTW Pretreatment Program Audit Results
- Audit Date
- Number of Categorical Ills
- Number of Significant Noncategorical lUs
- Legal Authority Adequacy
- Number/Percent IDs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of IU's Demonstrating Significant Noncompliance
- Annual Funding of the POTW Pretreatment Program
- FTEs Committed to the POTW Pretreatment Program
- Audit Results (i.e., Adequacy of POTW Legal Authority,
Compliance Monitoring and Enforcement, Resources, etc.)
- Type of Approval Authority Follow-up (i.e., Enforcement)
Environmental Impact Results
- Sludge Quality and Disposal
- Method of Disposal
- Priority Pollutant Concentrations
- NPDES Permit Compliance
- Total Number of Permit Violations
- Number Contributed to by lUs
- Treatment Plant Inhibition/Interference
- Number of Incidents in Past Year
- Priority Pollutant Loadings
- Average Influent Concentation
- Average Effluent Concentration
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or IU level).
A-3
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Tracking System Objective; Evaluate EPA Regional Oversight
Effectiveness
Priority Ranking: 2
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. Oversight Activities of POTW Pretreatment Programs
- Number of PCIs Performed
- POTWs for Which PCIs Have Been Per-formed
- Dates of PCIs Performed
- Enforcement Actions Taken as a Result of PCIs (i.e., Number
of Administrative Orders Issued, Number of Compliance
Schedules Issued)
- Number of Audits Performed
- POTWs for Which Audits Have Been Performed
- Dates of Audits Performed
- Enforcement Actions Taken as a Result of Audits (i.e.,
Number of Administrative Orders Issued, Number of
Compliance Schedules Issued)
- Number of POTWs Required to Submit Annual Reports
- Number of Annual Reports Received/Reviewed
2. Industrial User (IU) Compliance Data (by Category)
- Number of lUs Subject to Categorical Standards (by
Category)
- Number/Percent of lUs in Compliance With Categorical
Standards (by Category)
- Number/Percent of lUs in Compliance With Categorical
Standard Self-Monitoring and Reporting Requirements
- Number of-Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent of lUs in Compliance With All Applicable
Standards
- Number/Percent of lUs Demonstrating Significant Noncompliance
3. Delegated State Pretreatment Program Audit Activities
- Number of State Audits Performed
- States for Which Audits Have Been Performed
- Dates.of State Audits Performed
- Enforcement Actions Taken as a Result of the State Audits
A-4
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4. Control Authority Implementation by the Approval Authority
- Number of Categorical lUs Regulated (By Category)
- Number of Noncategorical (Significant) lUs
- IU Compliance Status
- Inspection and Sampling Activities (i.e., Percent of IDs
Monitored)
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-5
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Tracking System Objective; Evaluate POTW Program Effectiveness
Priority Ranking; 2
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
l. Industrial User Compliance Data
- Number of lUs Subject to Categorical Standards {By
Category)
- Number/Percent of lUs in Compliance With Categorical
Standards (By Category)
- Number/Percent of lUs in Compliance with Categorical
Standard Self-Monitoring and Reporting Requirements
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent of lUs in Compliance With All Applicable
Standards
- Number/Percent of IDs Demonstrating Significant Noncompliance
2. Environmental Impact Results
- Sludge Quality and Disposal
- Method of Disposal
- Priority Pollutant Concentrations
- NPDES Permit Compliance
- Total Number of Permit Violatins
- Number Contributed to by lUs
- Treatment Plant Inhibition/Interference
- Number of Incidents in Past Year
- Priority Pollutant Loadings
- Average.Influent Concentation
- Average Effluent Concentration
3. POTW Pretreatment Compliance Inspection (PCI) Results
- PCI Date
- Number of Categorical lUs
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent 10s Not Sampled Within Past Year
- Number/Percent of lUs Demonstrating Significant Noncompliance
- Type of Enforcement Follow-up Taken By Approval Authority
A-6
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POTW Pretreatment Program Audit Results
- Audit Date
- Number of Categorical lUs
- Number of Significant lUs
- Legal Authority Adequacy
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of IU's Demonstrating Significant Noncompliance
- Annual Funding of the POTW Pretreatment Program
- FTEs Committed to the POTW Pretreatment Program
- Audit Results (i.e., Adequacy of POTW Legal Authority,
Compliance Monitoring and Enforcement, Resources, etc.)
- Type of Approval Authority Follow-up (i.e., Enforcement)
POTW Annual Report Results
- Date Annual Report Required
- Date Annual Report Received
- Number of IU Inspections Performed
- Number of POTW Sampling Events Performed
- Number of lUs Subject to Categorical Standards
- Percent lUs in Compliance With Categorical Standards
- Percent lUs in Compliance With All Applicable Standards
*The amount"of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-7
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Tracking System Objective: Determine IU Compliance With
Categorical Standards
Priority Ranking: 2
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. Industrial User Compliance Data
(By
- Number of lUs Subject to Categorical Standards
Category)
- Number of lUs in Compliance With Categorical Standards (By
Category)
- Number of lUs in Compliance with Categorical Standard Self-
Monitoring and Reporting Requirements
- Number of Categorical IDs Demonstrating Significant Noncompliance
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-0
-------
Tracking System Objective; Evaluate State Program Effectiveness
Priority Ranking; 3
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. Oversight Activities of POTW Pretreatment Programs
- Number of PCIs Performed
- POTWs for Which PCIs Have Been Performed
- Dates of PCIs Performed
- Enforcement Action Taken
- Number of Audits Performed
- POTWs for Which Audits Have Been Performed
- Dates of Audits Performed
- Enforcement Action Taken
- Number of POTWs Required to Submit Annual Reports
- Number of Annual Reports Received/Reviewed
2. Industrial User (IU) Compliance Data
- Number of IDs Subject to Categorical Standards (By
Category)
- Number/Percent of lUs in Compliance With Categorical
Standards (By Category)
- Number/Percent of lUs in Compliance with Categorical
Standard Self-Monitoring and Reporting Requirements
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent of lUs in Compliance With All Applicable
Standards
- Number/Percent of lUs Demonstrating Significant Noncompliance
3. State Pretreatment Program Audit Results
- Audit Data
- Number of PCIs Performed
- Type of State Follow-up
- Number of Audits Performed
- Types of State Follow-up
- Number of POTW Annual Reports Received
- Number of Annual Reports Reviewed
- Number of Independent IU Compliance Inspections Performed
- Number of Categorical Industrial Users Where State is
Control Authority
- Number of Permits Issued by the State
- Number of Compliance Monitoring Events Performed by the State
-------
4. Control Authority Implementation by the Approval Authority
- Number of Categorical lUs Results (By Category)
- Number of Noncategorical (Significant) lUs
- IU Compliance Status
- Inspection and Sampling Activities (i.e., Percent of lUs
Monitored
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-10
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Tracking System Objective:
Priority Ranking; 4
Determine IU Compliance With Local
Limits
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. Industrial User Compliance Data
- Number of lUs Subject to Local Limits
- Number of lUs in Compliance With Local Limits
- Number of lUs Demonstrating Significant Noncompliance
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-ll
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Tracking System Objective: Develop Enforcement Strategies
Priority Ranking; 5
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. IU Compliance Data
- Number of lUs Subject to Categorical Standards (By
Category)
- Number/Percent of lUs in Compliance With Categorical
Standards (By Category)
- Number/Percent of lUs in Compliance with Categorical
Standard Self-Monitoring and Reporting Requirements
- Number of Significant Noncategorical lUs
- Total Number of Regulated IDs
- Number/Percent of lUs in Compliance With All Applicable
Standards
- Number/Percent of lUs Demonstrating Significant Noncompliance
2. POTW Pretreatment Compliance Inspection (PCI) Results
- PCI Date
- Number of Categorical lUs
- Number of Significant Noncategorical IDs
- Total Number of Regulated IDs
- Number/Percent lUs Without Control Mechanisms
- Number/Percent IDs Not inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of IIJs Demonstrating Significant Noncompliance
- Type of Enforcement Follow-up Taken By Approval Authority
3. POTW Pretreat-ment Program Audit Results
- Audit Date
- Number of Categorical IDs
- Number of Significant Noncategorical lUs
- Legal Authority Adequacy
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of lU's Demonstrating Significant Noncompliance
- Annual Funding of the POTW Pretreatment Program
- FTEs Committed to the POTW Pretreatment Program
- Audit Results (i.e., Adequacy of POTW Legal Authority,
Compliance Monitoring and Enforcement, Resources, etc.)
- Type of Approval Authority Follow-up (i.e., Enforcement)
A-12
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*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU Level).
A-13
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Tracking System Objective; Determine Industrial User Compliance
with Self-Monitoring Requirements
Priority Ranking; 6
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. Industrial User Compliance Data
- Number of lUs Subject to Self-Monitoring Requirements
- Number of lUs in Compliance With All Self-Monitoring
Requirements
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the POTW level).
A-14
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Tracking System Objective; Evaluate/Refine Existing Programs
Priority Ranking; 7
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. POTW Biographical Data
- POTW Name
- POTW Address
- NPDES Permit Number
- Total POTW Flow
- Percent Industrial Flow
- Date Program Submitted
- Date Program Approved
- Number of Categorical Industries by Category
- Number of Significant Noncategorical Industries
- Removal Credit Application Date
- Removal Credit Approval Date
Industrial User Compliance Data
(By
- Number of lUs Subject to Categorical Standards
Category)
- Number/Percent of lUs in Compliance With Categorical
Standards (By Category)
- Number/Percent of lUs in Compliance With Categorical
Standard Self-Monitoring and Reporting Requirements
- Number of Significant (Noncategorical) lUs
- Total Number of Regulated lUs
- Number/Percent of lUs in Compliance With All Applicable
Standards .
- Number/Percent of lUs Demonstrating Significant Noncompliance
3. POTW Pretreatment Compliance Inspection (PCI) Results
- PCI Date
- Number of Categorical lUs
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of lUs Demonstrating Significant Noncompliance
- Type of Enforcement Follow-up Taken By Approval Authority
A-15
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4. POTW Pretreatment Audit Results
- Audit Date
- Number of Categorical lUs
- Number of Significant Noncategorical lUs
- Legal Authority Adequacies
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Per cent of Ill's Demonstrating Significant Noncompliance
- Annual Funding of the POTW Pretreatment Program
- FTEs Committed to the POTW Pretreatment Program
- Audit Results (i.e., Adequacy of POTW Legal Authority,
Compliance Monitoring and Enforcement, Resources, etc.)
- Type of Approval Authority Follow-up (i.e., Enforcement)
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-16
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Tracking System Objective; Allocate EPA Resources
Priority Ranking: 8
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. POTW Biographical Data
- Number 'of POTW Pretreatment Programs Required
- Number of POTW Programs Where EPA is Approval Authority
' - Number of Approved POTW Programs Where EPA is Approval
Authority
- Number of Removal Credit Applications Received
- Number Removal Credit Applications Approved
2. Oversight Activities of POTW Pretreatment Programs
- Number of PCIs Conducted
- Number of Audits Conducted
- Number of Annual Reports Received
- Number of Annual Reports Reviewed
3. Control Authority Implementation By the Approval Authority
- Number of Regulated lUs Where Region is Control Authority
- Number of Industrial User Compliance Inspections Performed
4. Delegated State Pretreatment Program Audit Activities
- Number of State Audits Performed
- States for Which Audits Have Been Performed
- Dates of State Audits Performed
- Enforcement Actions Taken as a Result of the State Audits
*The amount "of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-17
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Tracking System Objective; Make National Policy Decisions
Priority Ranking: 9
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. POTW Biographical Data
- POTW Name
- POTW Address
- NPDES Permit Number
- Total POTW Flow
- Percent Industrial Flow
- Date Program Submitted
- Date Program Approved
- Number of Categorical Industries by Category
- Number of Significant Noncategorical Industries
- Removal Credit Application Date
- Removal Credit Approval Date
2. Industrial User Compliance Data
- Number of lUs Subject to Catgorical standards (By Category)
- Number of lUs in Compliance With Categorical Standards (By
Category)
- Number of IDs in Compliance With Categorical Standard Self-
Monitoring and Reporting Requirements
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent of IDs in Compliance With All Applicable
Standards
- Number of.. lUs Demonstrating Significant Noncompliance
3. Unique POTW Data
- Quantities of Hazardous Waste Received
- Basis for Local Limits
- Sludge Disposal Methods
- Summary of POTW Interference Problems
- Summary of POTW Pass Through Problems
*The amount of data collected for each measurement and data type
may . depend onthe level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-1C
-------
r
Tracking System Objective; Develop National Guidance
Priority Ranking; 10
Potential Measurements and Associated Data Types (In Order of
Relative Importance)*
1. POTW Pretreatment Compliance Inspection (PCI) Results
- PCI Date
- Number of Categorical Ills
- Number of Significant Noncategorical lUs
- Total Number of Regulated lUs
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected within Past Year
- Number/Percent lUs Not Sampled within Past Year
- Number/Percent of lUs Demonstrating Significant Noncompliance
- Type of Enforcement Follow-up Taken By Approval Authority
2. POTW Pretreatment Audit Results
- Audit Date
- Number of Categorical lUs
- Number of Significant Noncategorical lUs
- Legal Authority Adequacy
- Number/Percent lUs Without Control Mechanisms
- Number/Percent lUs Not Inspected Within Past Year
- Number/Percent lUs Not Sampled Within Past Year
- Number/Percent of IU's Demonstrating Significant Noncompliance
- Annual Funding of the POTW Pretreatment Program
- FTEs Committed to the POTW Pretreatment Program
- Audit Results (i.e., Adequacy of POTW Legal Authority,
Compliance Monitoring and Enforcement, Resources, etc.)
- Type of Approval Authority Follow-up (i.e., Enforcement)
*The amount of data collected for each measurement and data type
may depend on the level at which the data will be summarized
(i.e., Region, State, POTW, or at the IU level).
A-19
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ATTACHMENT B
EPA REGION AND STATE CONTACTS
-------
Name
EPA REGION AND STATE CONTACTS
Affiliation
Bob Townsend
(for Joe Kelleher)
Ken Goldstein
Jerry Cain
Doug Finan
Ron Duff
(for Jeff Barnickol)
Don Schredargus
Dave Rankin
Alicia Diaz-Costa
{for Roger Hartung)
Keith Silva
Bob Robichaud
New York State Department of
Environmental Conservation
New Jersey Department of
Environmental Protection
Mississippi Department of
Natural Resources
North Carolina Department of
Natural Resources and
Community Development
California State Water
Resources Control Board
EPA Region V
EPA Region V
(formerly with Ohio EPA)
EPA Region VI
EPA Region IX
EPA Region X
B-l
-------
ATTACHMENT C
POTENTIAL MEASUREMENTS FOR EPA REGIONS AND STATES
INFORMATION NEEDS
-------
TABLE C-1. SUMMARY OF POTENTIAL MEASUREMENTS FOR EPA REGIONS AND DELEGATED
PRETREATMENT STATES PRETREATHENT TRACKING NEEDS
Tracking Evaluate Local (POTW)
System Program Effectiveness
Needs
Determine Industrial Determine Industrial Determine Industrial Evaluate State
User Compliance With User Compliance With User Compliance With Program
Categorical Standards Local Limits Self-Monitoring Effectiveness
Potential
Measurements
POTW Biographical
Data
POTW Pretreatment
Compliance
Inspection
(PCI) Results
POTW Pretreatment
Program Audit
Results
POTW Annual Report
Results
Industrial User
Compliance Data
Oversight Activi-
ties of POTW
Pretreatment
Programs
State Pretreatment
Program Evaluation
Results
Control Authority
Implementation by
the Approval
Authority
C-1
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ATTACHMENT D
NATIONAL PRETREATMENT TRACKING SYSTEM ACTIVITIES
AND DATA REQUIREMENTS
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PART III: EVALUATION OF ALTERNATIVES FOR THE PRETREATMENT
PERMITS AND ENFORCEMENT TRACKING SYSTEM
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TABLE OF CONTENTS
Page
I. INTRODUCTION 1-1
A. Alternative 1: No National Automated System
for Pretreatment Enforcement Tracking ... 1-2
B. Alternative 2: EPA Oversight System
(Headquarters and Regions) 1-6
C. Alternative 3: System for Approval Authorities
and Higher Levels 1-11
D. Alternative 4: System for Approval Authorities
and Higher Levels (With Limited
User Data) 1-15
E. Alternative 5: System for Approval Authorities
and Higher Levels (With Extensive
Industrial User Data) ..... 1-20
II. EVALUATION OF PPETS ALTERNATIVES II-l
A. Tracking System Objectives 11-2
B. Data Availability Criteria ........ II-5
C. System Capability Criteria II-9
D. Lifecycle Cost Criteria 11-12
E. Technical Criteria . . 11-25
F. Timeline Criteria 11-28
G. Change Potential Criteria . . 11-33
H. Organizational Impact Criteria .... 11-36
III. CONCLUSIONS AND RECOMMENDATION III-l
APPENDIX A A-l
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1-1
I. INTRODUCTION AND DESCRIPTION OF PPETS ALTERNATIVES
As a result of the needs expressed by EPA officials in the Summary of
Pretreatment Tracking Needs, five possible alternatives were Identified for a
Pretreatment Permits and Enforcement Tracking System (PPETS). These
alternatives cover a wide variety of informational needs and cost constraints.
This document evaluates the proposed systems and presents the strengths,
weaknesses, and possible impacts of each. The analysis is designed to help
EPA decide on the best option to pursue. This is an important step toward an
initial system design and full feasibility study.
Section I of this document is divided into five parts, each of which
discusses one of the five PPETS alternatives; they are:
• Alternative 1: No National Automated System for Pretreatment
Enforcement Tracking
• Alternative 2: EPA Oversight System (Headquarters and Regions)
• Alternative 3: System for Approval Authorities and Higher Levels
t Alternative 4: System for Approval Authorities and Higher Levels
(with Limited IU Data)
• Alternative 5: System for Approval Authorities and Higher Levels
(with Extensive IU Data)
The discussion of each alternative includes a complete written description, a
diagram of the major data flows, and an exhibit listing suggested data
elements to be tracked.
Section II of the document then analyzes each of the alternatives and
compares them using a broad range of criteria. The criteria considered
include: tracking system objectives, data availability, system capability,
system lifecycle cost, technical capabilities, time frames, change potential,
and organizational impact.
Section III presents conclusions about the five Pretreatment Permits and
Enforcement Tracking System alternatives. A recommendation is provided about
the courses of action EPA may pursue.
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1-2
A. Alternative 1:No National Automated System for Pretreatment Enforcement
Tracking
The status quo for tracking and evaluating the National Pretreatment
Program (NPP) partly meets some of the needs identified by EPA Headquarters
staff in the Summary of Pretreatment Tracking Needs. Certain needs cannot now
be met at all, others can be met manually, and a few can be addressed with the
help of existing automated systems.
There are many pretreatment-related information management activities now
undertaken at a variety of organizational levels. Most Control Authorities
submit Annual Reports to their Approval Authorities. These Annual Reports can
vary in content, and may or may not be forwarded to EPA Regional Offices.
Approval Authorities also generate data themselves from their POTW oversight
activities — Pretreatment Compliance Inspections (PCIs) and Pretreatment
Program Audits. The Approval Authority is required to automate some of the
data from both these processes by entering them into PCS.
EPA Headquarters has issued guidances for Annual Reports, PCIs, and
Program Audits. There are also suggested formats for Pretreatment Performance
Summaries (to be included with Annual Reports), PCI checklists, and Program
Audit checklists. However, these formats and guidances are not mandatory, and
the actual report contents can vary by Approval Authority.
Many of the specific pretreatment tracking needs identified by EPA
Headquarters personnel can now be met, though only by manual data collection,
tabulation, and analysis. For example, the effectiveness of a set of local
POTW programs can be assessed only by manually collecting and examining the
Annual Reports, Pretreatment Compliance Inspections (PCIs) and Program Audits.
Unfortunately, use of manual procedures is often time consuming, expensive,
and subject to-significant errors and omissions in spite of the best efforts
of EPA, State, and POTW personnel.
Currently, very limited data is stored in PCS about PCIs and Program
Audits. This data is not sufficient to support many needs identified by EPA
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1-3
personnel. For example, determining Industrial User (IU) compliance with
categorical standards is a high priority need, but no national totals can be
easily developed now for categorical compliance. Similarly, development of
enforcement strategies is difficult without national statistics comparing POTW
enforcement actions with results at the Industrial User level. These needs
could, if necessary, be met through special data collection efforts (e.g.,
telephone surveys of all EPA Regions), although the resulting information is
likely to be incomplete and inconsistent.
In spite of the regular data flows that now exist, the status quo can be
characterized as suboptimal for pretreatraent tracking. Data are widely
dispersed, in varying formats, and are not fully automated. Certain Regions
and States have developed their own tracking systems for pretreatment data;
some of these systems automate data down to the lU-level. Most POTWs rely on
manual systems, and are adapting Enforcement Management System (EMS)
principles from the NPOES program according to EPA guidance.
Exhibit I-1A summarizes data flows under the current pretreatment system.
Exhibit I-1B shows the general category of pretreatment data currently stored
in PCS. A list of all the pretreatment tracking data elements currently
stored in PCS is in Appendix A.
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EXHIBIT MB:
Data Contained In Alternative 1
Source: Pretreatment Compliance Inspections and Program Audits
The following data is already contained in PCS:
• Counts of PCIs and Program Audits
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1-6
B. Alternative 2; EPA Oversight System (Headquarters and Regions)
This alternative addresses the pretreatment tracking requirements to
assist the EPA Headquarters and Regions with their oversight roles. For the
most part, this alternative does not focus on the more detailed needs of the
States and the Approval and Control Authorities.
In particular, this alternative should help EPA:
• Determine Overall Effectiveness of the National Pretreatment Program
(NPP)
• Evaluate Regional Oversight Effectiveness
• Assess POTW Enforcement of Pretreatment Regulations
• Determine Overall Industrial User Compliance
• Develop National Policy and Enforcement Strategies
In order to meet these needs, the system will rely on the information in
one recently proposed report — the POTW Pretreatment Performance Summary
(PPS). EPA has issued a draft Pretreatment Compliance Monitoring and
Enforcement Guidance document which proposes that a PPS be included with each
POTW Annual Report submitted to an Approval Authority. The guidance includes
a suggested format and a list of the minimal information to be contained in
each PPS. The Pretreatment Performance Summary is essentially a one-page
statistical summary and contains information on:
• General POTW Characteristics
• Significant Industrial User Compliance
• The POTW's Compliance-Monitoring Program
t Enforcement Actions Undertaken by the POTW
These minimal data items, which will be readily available, can help meet
many EPA-specific pretreatment tracking needs. It will be necessary, though,
to make the information contained in the Pretreatment Performance Summary
mandatory, rather than optional. Fully standardized report formats,
submission deadlines, and data elements will be needed to support a consistent
tracking system.
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1-7
The proposed system could be implemented on the EPA IBM mainframe and
connected to the EPA Regions via terminals and telecommunication lines. The
data to be tracked by Alternative 2 will have greater utility when combined
with NPDES data already in PCS. In order to ensure complete compatibility
between the systems, Alternative 2 should be designed as a separate data file
in an expanded PCS.
Under this alternative, each EPA Regional Office would be responsible for
entering the PPS data for the POTWs within its jurisdiction. User-friendly
software procedures will be provided to speed data entry. The number of POTW
Pretreatment Performance Summaries to be entered by each Region will vary from
about 20 to 400 per year.
This system would provide EPA Headquarters and Regions with periodic
reports summarizing the PPS data nationwide, region-wide, statewide, and even
by POTW. In addition, users could enter specific queries for data not
precisely covered in the summary reports. These user query reports will take
less than a day to process, and some may take only a few minutes, depending
upon the complexity of the request. Among its uses, this data will help to
point out problem areas in pretreatment enforcement and allow EPA to
concentrate their efforts in these areas.
Implementation of this proposed system would require several changes in
the status quo. For one, it would be crucial for the Pretreatment Performance
Summaries to be passed from delegated State Approval Authorities to their
responsible EPA Regions. In addition, it will be necessary to require the
information on the Pretreatment Performance Summary be compiled at least once
a year to be included with the POTW Annual Report. If more frequent data
updates are required, some new reporting procedures may have to be
established.
A limited .tracking system of this sort would require relatively few
personnel resources to maintain and almost no purchases of new equipment. The
data could also be made available to existing microcomputers through
downloading capabilities.
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1-8
Exhibit I-2A Illustrates the major data flows in this alternative.
Exhibit I-2B lists the categories of data from the Pretreatment Performance
Summary suggested format that could be tracked by this system. A detailed
list of all the data elements in the PPS suggested format that could be
tracked by Alternative 2 is contained in Appendix A.
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EXHIBIT I-2B:
Data to be Contained In Alternative 2
Source: PCI and Program Audit Data Currently In PCS
• Counts of PCIs and Program Audits
Source: POTW Pretreatment Performance Summary
Alternative 2 will contain all of the data in the EPA guidance
suggested format for Pretreatment Performance Summaries, including:
• Geographic Information About POTWs and Counts of lUs
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users)
• Compliance Monitoring Program Data (Summary level only)
• Enforcement Actions Data (Summary level only)
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1-11
Alternative 3; System for Approval Authorities and Higher Levels
This proposed system addresses many of the pretreatment tracking needs
identified in the Summary of Pretreatment Tracking Needs. It is more
comprehensive than the EPA Oversight System previously discussed. It offers
all the features of the previous system, and in addition, it helps relevant
organizational levels:
• Determine POTW Compliance with Pretreatment Program
Implementation Requirements
• Evaluate State Program Effectiveness
• Evaluate Local Program Effectiveness
• Determine Compliance Rate of Significant Industrial Users With
Pretreatment Standards
• Allocate EPA Resources and Refine Existing Programs
In order to support these diverse needs, the system requires extensive
data. PCIs, Program Audit results, and POTW Pretreatment Performance
Summaries will all be necessary. Fortunately, all these types of data will be
gathered at one organizational level ~ the Approval Authority. For this
reason, the Approval Authority is the most reasonable choice as the party
responsible for data entry. No reports, other than those mentioned above,
will be necessary for implementation of this system. However, the frequency
and information contained in those reports will have to be standardized.
Much of the data to be tracked by Alternative 3 will have greater utility
when combined with NPDES data already in PCS. Therefore, PCS would be a
logical choice as a "home" for this automated pretreatment data. Also, EPA
Regions and several Approval Authorities already enter summary PCI and POTW
Program Audit data into PCS. Although the pretreatment tracking system will
require more detailed PCI and Audit data, these offices already have staff
familiar with PCS routines, which should facilitate future use of the PPETS
system.
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1-12
It is hoped that Alternative 3 will attract delegated State Approval
Authorities to become users. The system will provide these states with an
automated means of assessing pretreatment and permit enforcement in their
jurisdictions. The system will provide EPA Headquarters, Regions, and
participating Approval Authorities with periodic standard reports and
user-designed reports. It will help to pinpoint problem POTWs and allow
resources to be expended where they are needed most. If a State Approval
Authority decides not to participate in PPETS, then the data required for that
state will have to be entered by the EPA Regional Office.
For PPETS to be successful and encourage State Approval Authority
participation, it will have to be user-friendly. The data should be
accessible to all program staff at EPA Headquarters, Regions, and Approval
Authorities ~ even for those personnel who are untrained in computer
programming. The additional software routines should also be compatible with
PCS, so that personnel currently using PCS will have no trouble learning the
new system.
This pretreatment tracking system concept will require some significant
modifications to PCS, The alternative may require several new data files and
an expansion or connection to some current PCS files. However, PCS data
structures have proven themselves flexible in the past with the expansion of
PCS subject matter to include evidentiary hearing and grant information. The
exact nature and content of the new and expanded data files will have to be
decided by EPA and State authorities.
Exhibit I-3A illustrates the major data flows in this alternative.
Exhibit I-3B lists suggested categories of data items to be tracked by this
system. A detailed set of suggested data items to be tracked by Alternative 3
is listed in Appendix A.
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1-13
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EXHIBIT I-3B:
Data to be Contained in Alternative 3
Source: POTW Pretreatment Performance Summary
Alternative 3 will contain the same data from the Pretreatment
Performance Summaries as Alternative 2, including:
• Geographic Information About POTWs and Counts of lUs
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users)
• Compliance Monitoring Program Data (Summary level only)
t Enforcement Action Data (Summary level only)
Source: Pretreatment Compliance Inspections and Program Audits
Alternative 3 will contain data from the EPA guidance suggested formats
for PCI and Program Audit checklists, including:
• PCI / Audit Identification Data
• Control Authority Pretreatment Program Overview Data (Summary
level only)
• Control Authority Inspection and Monitoring of Industrial Users
(Summary level only)
• Count of SIUs Covered by a Control Mechanism
• IU Compliance and Enforcement Actions (Summary level only)
t IU File Evaluation Data (Summary level only)
• - 'Evaluation Comments of Inspector/Auditor (May include a possible
code to rank areas of POTW activity)
t Background Control Authority Data
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1-15
i
0. Alternative 4: System for Approval Authorities and Higher Levels
(Ulth Limited Industrial User Data)
This proposed system is very similar to the previous alternative, but with
some additions to make it more useful to Approval Authorities. Like the
previous systems, it will support the following functions:
• Determine Overall Effectiveness of the National Pretreatment Program
• Evaluate Regional and Approval Authority Oversight Effectiveness
• Determine POTW Enforcement of Pretreatment Program Requirements and
the Overall Compliance of Industrial Users
• Allocate EPA Resources and Refine Existing Programs
• Develop National Policy and Enforcement Strategies
In addition, it will also allow Approval Authorities to store and
manipulate limited amounts of Industrial User data. This system is intended
to assist those Approval Authorities that also act as. Control Authorities.
Specific data about critical groups of Industrial Users could be tracked,
including:
• Required Reports on IU Compliance
• Effluent and Concentration Levels
• Monitoring Samples Data
• Enforcement Actions
As with Alternative 3, it seems logical to incorporate this system into
PCS. However, since the number of Industrial Users is very large, and to
avoid impairing PCS operations, not all lUs could be tracked. Only those
Categorical lUs where the State or Region acts as the Control Authority should
be entered. It is estimated that approximately 1500 Categorical Industrial
Users would be. tracked in this system, and that this should not harm PCS
operation or performance.
Alternative 4 will provide periodic standard and user-designed reports to
help EPA Headquarters, Regions, and participating Approval Authorities
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1-16
oversee the permits and enforcement actions of POTWs. It will also allow
Approval Authorities to monitor the compliance of those Industrial Users for
which it acts as Control Authority. EPA users could design reports with
statistics on a National, Regional, State, POTW, and Industrial User level.
The Industrial User data in Alternative 4 will be implemented using
existing PCS software. Programs already used by PCS will be modified to allow
Industrial User tracking. This will be significantly less expensive than
creating a new system just for IUs.
However, since the PCS software was designed for tracking POTWs and not
lUs, there will be certain restrictions on the types of data stored. Only
those data types which correspond to PCS data could be tracked. Fortunately,
there are many similarities between tracking POTW effluent compliance and IU
effluent compliance. Some data, such as production based limits, may be
difficult to track.
Exhibit I-4A illustrates the . major data flows in this alternative.
Exhibit I-4B lists suggested categories of data to be tracked by this system.
A detailed set of suggested data items to be tracked by Alternative 4 is
listed in Appendix A.
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1-17
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1-18
EXHIBIT I-4B:
Data to be Contained in Alternative 4
Source: POTW Pretreatment Performance Summary
Alternative 4 will contain the same data from the Pretreatment
Performance Summaries as Alternative 2, including:
• Geographic Information About POTWs and Counts of lUs
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users)
• Compliance Monitoring Program Data (Summary level only)
• Enforcement Action Data (Summary level only)
Source: Pretreatment Compliance Inspections and Program Audits
Alternative 4 will contain the same data from Pretreatment Compliance
Inspections and Program Audits as Alternative 3, including:
• PCI / Audit Identification Data
• Control Authority Pretreatment Program Overview Data (Summary
level only)
• Control Authority Inspection and Monitoring of Industrial Users
(Summary level only)
• Count of SIUs Covered by a Control Mechanism
• III Compliance and Enforcement Actions (Summary level only)
• IU File Evaluation Data (Summary level only)
• -"Evaluation Comments of Inspector/Auditor (May include a possible
code to rank areas of POTW activity)
• Background Control Authority Data
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1-19
Alternative 4, continued
\
Source: Various Industrial User Reports
In Alternative 4, Industrial User data will only be tracked for lUs
where the State or Regional Approval Authority also acts as the Control
Authority.
• General Industrial User Identification Data
• Sampling and Reporting Requirements (Detailed data)
• Pollutant Limits Data (Detailed data)
t Monitoring Data (Detailed data)
t Industrial User Technological Compliance Schedule
• Date and Type of IU Inspections by Control Authority
• Slug Load Data
• Enforcement Actions Taken (Detailed data)
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1-20
E. Alternative 5; System for Approval Authorities and Higher Levels
(With Extensive Industrial User Data)
This system Is essentially an extension of Alternative 4. It will contain
all the capabilities of the previous system, including determining the overall
effectiveness of programs and oversight functions, determining overall IU
compliance, assisting in resource allocation, and developing guidance. This
system would also allow all Approval Authorities to track data for any number
of Industrial Users.
The data tracked for Industrial Users would include: compliance records,
effluent and concentration levels, monitoring samples data, IU inspection
data, and enforcement actions.
Approval Authorities would have the system availability to track all
Industrial Users. Since the data storage requirements for Industrial User
data have the potential for being very large, this part of the system would
not be implemented on PCS. To do so could very possibly overload PCS
capabilities and impair existing PCS operations.
Under this alternative, PCS would be expanded to include all of the new
pretreatment tracking -data, except the Industrial User data. The Industrial
User data would be stored on the EPA IBM mainframe, but in a separate system
that could be linked to PCS.
Each participating Approval Authority would decide how much Industrial
User data to enter. They would have the option to enter data for any number
of lUs and as extensively detailed data as necessary. Approval Authorities
could use the system to track only a specific subset of lUs or to provide
comprehensive statistics about all lUs. EPA Headquarters and Regions would be
able to produce national and regional pretreatment enforcement and permits
statistics for POTWs and those lUs in the system.
Because of the additional IU data, Alternative 5 would be considerably
larger than the other options. It would cost much more to implement and
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1-21
maintain, but the amount of pretreatment compliance"and permit data available
would be greater than under the other alternatives.
Exhibit I-5A illustrates the major data flows in this alternative.
Exhibit I-5B lists suggested categories of data to be tracked by this system.
A detailed set of suggested data items to be tracked by Alternative 5 is
listed in Appendix A.
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1-22
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EXHIBIT I-5B:
Data to be Contained in Alternative 5
Source: POTW Pretreatment Performance Summary
Alternative 5 will contain the same data from the Pretreatment
Performance Summaries as Alternative 2, including:
t Geographic Information About POTWs and Counts of Ills
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users)
• Compliance Monitoring Program Data (Summary level only)
• Enforcement Action Data (Summary level only)
Source: Pretreatment Compliance Inspections and Program Audits
Alternative 5 will contain the same data from Pretreatment Compliance
Inspections and Program Audits as Alternative 3, including:
• PCI / Audit Identification Data
• Control Authority Pretreatment Program Overview Data (Summary
level only)
• Control Authority Inspection and Monitoring of Industrial Users
(Summary level only)
• Count of SIUs Covered by a Control Mechanism
• IU Compliance and Enforcement Actions (Summary level only)
• IU File Evaluation Data (Summary level only)
• "Evaluation Comments of Inspector/Auditor (May include a possible
code to rank areas of POTW activity)
• Background Control Authority Data
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1-24
Alternative 5, continued
Source: Various Industrial User Reports
In Alternative 5, participating Approval Authorities will decide which
Industrial Users and how much data they will track.
• General Industrial User Identification Data
• Sampling and Reporting Requirements (Detailed data)
• Pollutant Limits Data (Detailed data)
• .Monitoring Data (Detailed data)
• Industrial User Technological Compliance Schedule
t Inspections of Industrial Users by Control Authority
• Slug Load Data
• Enforcement Actions Taken (Detailed data)
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II-l
II. EVALUATION OF PPETS ALTERNATIVES
This section of the document evaluates all of the PPETS alternatives
for a wide range of criteria. The section is composed of eight parts.
Each part deals with a single class of evaluation criteria. They are:
Tracking System Objectives: the data needs of EPA users that will
be satisfied by each alternative
Data Availability Criteria: the accessibility of the data required
for each alternative
System Capability Criteria: general
capabilities of each alternative
system and reporting
• Lifecycle Cost Criteria: the dollar and staff costs of development
and five years of operations for the PPETS system
• Technical Criteria: the technical capabilities of the system to
meet user needs
• Timeline Criteria: the time frame necessary for development of
each alternative
• Change Potential Criteria: the flexibility of each alternative to
meet changes in EPA's needs
• Organizational Impact Criteria: the major effects each alternative
will have on EPA organizations
Each part fully evaluates all of the alternatives with regard to a
class of criteria. In addition, each part contains a table summarizing the
results of the analysis.
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II-2
Tracking System Objectives
In the Summary of Pretreatment Tracking Needs, EPA Headquarters,
Regional Offices, and Approval Authorities identified their priority
objectives for the Pretreatment Permits and Enforcement Tracking System
(PPETS). Exhibit II-l lists all of these objectives and illustrates how
well each of the proposed alternatives satisfies them.
The top part of the chart lists out each of the identified objectives
along with their associated priority number (this priority number was
calculated as part of the tracking needs document). The first two rows of
the chart identify the organizations which will benefit from fulfilling
these objectives.
Alternative 1, the current system, does not satisfy most of these
objectives. It provides slight support for three of the objectives, but
this support is minimal.
Alternative 2 fully supports two of the most important oversight
objectives:
• Determine Overall Effectiveness of National Program
• Evaluate EPA Regional Oversight Effectiveness
In addition, Alternative 2 also provides partial support for many of the
other objectives. These other objectives are only partially supported in
Alternative 2 due to the lack of PCI and Program Audit data and because of
the highly aggregate nature of the statistics on the PPS.
Alternative 3 provides much more comprehensive coverage of the
objectives than Alternative 2. It fully supports the same objectives as
Alternative 2 and also fully supports seven others, including:
• Evaluate Local Program Effectiveness
• Evaluate State Program Effectiveness
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II-3
• Develop Enforcement Strategies
• Evaluate/Refine Existing Programs
- • Allocate EPA Resources
• Make National Policy Decisions
« Determine POTW Compliance with Pretreatment Program
Implementation Requirements
Alternative 3 also provides partial support for all the rest of the
identified objectives.
In addition to the data in Alternative 3, Alternative 4 also tracks
data for a limited number of Categorical Industrial Users. Alternative 4
fully supports the same objectives that Alternative 3 does. In addition,
Alternative 4 fully supports 4 more objectives, but only for the subset of
Industrial Users that it tracks:
• Determine Industrial User Compliance with Categorical
Standards
• Determine Industrial User Compliance with Local Limits
• Determine IU Compliance with Self-monitoring
Requirements
• Determine IU Compliance with Applicable Pretreatment
Standards and Requirements
Alternative r5 is the most comprehensive of all the proposed systems.
It will track PPS, PCI, and Program Audit data, and a complete range of
Industrial User data. If provided with sufficient Industrial User data,
Alternative 5 could fully support all of the objectives identified in the
Summary of Pretreatment Tracking Needs document.
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II-5
8. Data Availability Criteria
Data availability refers to the accessibility of the required data for
each of the alternatives. Criteria to be considered include:
t Type of required data, including the specific reports which
will supply the data
• Source of required data, including the organizations that are
responsible for compiling and supplying the reports
• Basis for current data collection, including the purpose for
presently compiling the reports, whether due to EPA regula-
tions, guidances, local needs, etc.
• Frequency of data generation, including how often the reports
are currently compiled
• Data format, including how the data is currently arranged and
reported
• Data accuracy and timeliness, including the reliability of
the data to reflect current pretreatment conditions
These criteria are summarized for all five alternatives in Exhibit
II-2. It should be remembered the alternatives build upon each other, and
each successive alternative includes all the data contained in its
predecessors.
Alternative 1 uses only very summary level data from PCIs and Program
Audits. This data is entered into PCS by the Approval Authorities or the
EPA Regions. In some cases, converter programs are used to transfer the
data from state systems to PCS. Program Audits are conducted once every
five jears and PCIs are conducted during non-audit years. PCS is usually
updated within one or two months to reflect the occurrence of PCIs and
Audits.
Alternative 2 contains all the data in Alternative 1 plus Control
Authority Pretreatment Performance Summaries (contained in Annual Reports).
Annual Reports are' produced by Control Authorities and submitted to
Approval Authorities; sometimes, copies are also sent to the Regions, even
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II-6
if they are not the Approval Authorities. EPA policy guidance suggests
that Annual Reports be submitted at least once a year; some Approval
Authorities require them more often (semi-annually or quarterly) and some
do not require them at all. The Pretreatment Performance Summaries are
statistical summaries to be included with the Annual Reports; EPA
guidelines contain a suggested format for the PPS report. For Alternative
2 to be viable, the information in the Pretreatment Performance Summaries
must have mandatory submission periods and formats. Since Pretreatment
Performance Summaries are only one page long, the resources required to
enter the information will not be very great. This data should be reported
in a timely manner to reflect the condition of the Control Authority as
accurately as possible.
Alternative 3 contains all the data mentioned above plus expanded PCI
and Program Audit data. Approval Authorities are required to conduct PCIs
and Program Audits of POTWs, and EPA has developed a suggested checklist
format. For this alternative to succeed, EPA will have to make some
information from its suggested checklists mandatory, in order to ensure
consistent data and measurements. Since the data to be entered into
Alternative 3 is much broader than for Alternative 2t the quality of the
data may vary across different Approval Authorities. It is, however, hoped
that the data will, in general, accurately describe Control Authority
programs and be timely.
Alternatives -4 and 5 contain all the data mentioned above plus
Industrial User data. The IU data required by the system is partially
generated by the Control Authorities and partially by the Industrial Users
themselves. The Control Authorities are responsible for conducting
inspections once or twice a year, taking periodic sampling measurements,
and performing an Industrial Waste Survey and periodic updates. The
Industrial Users are responsible for producing periodic compliance reports
(at least twice a year for Categorical lUs), self-monitoring sampling
reports as required by the POTW, and slug loading notices as dictated by
events. Although these reports are required for Categorical lUs under the
National Pretreatment Program, standardized data and formats have not been
established. If these alternatives are to be implemented, such
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II-7
standardized formats would be necessary. Alternative 4 would only require
standardized formats for Categorical Industrial Users where a State or
Region is the Control Authority. Alternative 5, however, would require
standardized formats for all Significant Industrial Users. Due to its size
and complexity, the Industrial User data will probably be subject to
greater uncertainty than other data in PPETS; its accuracy and timeliness
may vary somewhat between different Control Authorities and Industrial
Users.
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System Capability Criteria
System capability criteria refers to the PPETS system's capacity to
organize pretreatment data and to produce reports to satisfy EPA user
needs. A summary of the system capability criteria for all five
alternatives is contained in Exhibit II-3. The criteria considered
include:
• Analytic flexibility, including the different ways to organ-
ize the pretreatment enforcement and permits data in the
system
• Output Format, including the various types of reports that
can be produced by PPETS
• Interactive Characteristics, including the on-line reporting
and data entry capabilities of PPETS which permit direct user
access and response
Analytic flexibility refers to the capabilities of PPETS to allow users
to logically organize data in different ways. This is especially important
for reporting functions; ADABAS, the underlying implementation environment
of PCS, has a reputation for great flexibility in this area. Currently,
since there is very little pretreatment data in PCS, there is very little
flexibility on how to organize that data. Only general data about the
occurrence and dates of PCIs and Program Audits are presently available at
the POTW level, in PCS. Alternative 2 allows for greater analytic
flexibility. Data can be organized, or "cut", by State, POTW, type of
compliance (i.e^, reporting compliance, schedule compliance), monitoring
activities, enforcement activities, etc. Alternative 3 will have the same
major data cuts as Alternative 2, but in addition, the user would be able
to organize the data according to any of the PCI or Program Audit
parameters that will be tracked. Alternatives 4 and 5 will be able to be
cut by all the parameters previously mentioned, plus they will have
Industrial User data that could be cut by IU, categorical industry, amount
and type of effluents^ required reporting schedules, etc.
The previously mentioned data cuts are only the major logical
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11-10
organizations of the data. PCS has very flexible capabilities, and would
be able to organize the data in reports in almost any way the user
requires.
PCS has three major formats for output reports: standard batch reports,
user-designed or "quick-look" reports, and interactive user inquiries.
These three classes of reports will be the same for all the alternatives.
The exact format for many of the reports and reporting capabilities will be
determined as the PPETS system is designed. The Industrial User data in
Alternative 5, being stored in a system separate from PCS, may have a
greater variety of reporting capabilities; however, due to the large amount
of IU data, some of the interactive user inquiries may be difficult to
achieve.
Interactive characteristics may be of great importance to PPETS users.
Currently, PCS has the capability to run batch jobs and interactive inquiry
and data entry routines. Alternative 2 will probably have mostly batch
reports with quick turnaround times (less than one day). Interactive
capabilities may be expanded, although this may not be necessary.
Alternative 2 is a small system, so the number of inquiries may be limited
and the turnaround for batch reports may be sufficient. Alternative 3 is a
somewhat larger system and the demand for retrievals and interactive
processing may increase. For the larger systems, Alternatives 4 and 5, the
need for quick data retrievals and interactive processing may increase
significantly. This would be especially true for some of the IU data, like
compliance and reporting schedule data.
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11-11
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0. Llfecycle Cost Criteria
Lifecycle costs are the total expenditures EPA can expect to make for
staff costs, computer time, and equipment purchases during development and
five years of operations for the PPETS system. Lifecycle costs fall into
two major categories:
• Development costs, including all the one-time expenditures
directly associated with studying, designing, implementing,
and training users for the PPETS system
• Operating costs, including all of the recurring annual
expenses directly associated with entering data, maintaining,
supporting, and using the PPETS system.
Both of these categories are examined in great detail in the next two
sections.
Exhibit II-4 contains an overview of the total PPETS lifecycle costs.
There are estimates for development costs, first year operating costs, and
future year operating costs (years 2 through 5) for all of the proposed new
systems. There is a totals column listing the estimated costs that EPA can
expect to spend for development and five years of operation of each
alternative. All of the cost estimates have been listed out for time-
sharing expenditures and dollar expenditures for non-timesharing resources.
The estimates also assume that the initial year operating expenditures will
generallly be 3Q% higher than future years, due to system shake-down and
familiarizing new users with PPETS. The only exceptions to this are for
equipment maintenance costs, which are expected to be constant for each of
the first five years of operation. More information about the specific
cost."estimates and their underlying assumptions is contained in the next
two sections on development and operating costs.
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11-13
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1. Development Cost Criteria
Development costs include all those one-time costs that would be
directly associated with the development of.the PPETS system. These costs
would include:
• Personnel costs, including contractor and EPA staff costs
required for development, installation, and training
• Timesharing costs, including the costs for connect time,
processing, and telecommunications
• Travel costs, including per diem and transportation costs
• Required hardware costs, including the costs for new computer
equipment and peripherals
Dollar figures have been estimated for all of these cost criteria. In
general, the costs will vary depending upon the complexity of the system
being developed. Alternative 1, the current system, will obviously have no
development costs in any of the categories. Alternative 5, the most
complex of the proposed systems, will probably have the highest cost in
each category. These cost criteria are summarized for all the alternatives
in Exhibit II-5.
The cost estimates only include the direct system development expenses.
They do not include related programmatic costs such as the cost of altering
current pretreatment programs and permits to standardize reporting
practices, the cost to Control Authorities of compiling the required
pretreatment reports, or the cost of verifying the accuracy of PPS and
other pretreatment data.
Personnel "costs include the staff costs for preliminary studies,
design, implementation, installation, and training for the new system.
Personnel costs will be the most significant development costs and will
vary substantially with each alternative. The estimates for personnel
costs are in man-months and dollars for both contractor and EPA staff
resources. Contractor costs are assumed to be $7500 per man-month, which
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11-15
includes salary, overhead costs, general and administrative costs, fee, and
miscellaneous other direct costs. EPA staff personnel are assumed to be GS
13, step 1, at a salary of $37,000 per year.
Alternative 2 will have the smallest development cost of the proposed
new systems. It is a small tracking system that will be implemented as a
separate data file in PCS. The current PCS data files will probably
require little or no modifications in this alternative. The data elements
are relatively few and are well defined by the Control Authority
Pretreatment Performance Summary sample contained in the EPA Pretreatment
Compliance Monitoring and Enforcement Guidance. This system will require
very little preliminary work before actual programming could begin.
Estimates for contractor resources are from 4 to 6 man-months or $30,000 to
$45,000, and estimates for EPA personnel resources are from 1 to 2
man-months or $3100 to $6200.
Alternative 3 will have significantly higher personnel development
costs. Adding PCI and Program Audit data and extending the system to the
states will make this option more complex than the previous alternative.
EPA has issued a guidance for PCIs and Program Audits that contain
extensive checklists and suggested procedures. Not all the data contained
on the checklists should be tracked in PPETS. For example, some questions
refer to the establishment of POTW legal authority and written enforcement
procedures. This information is important for EPA at the present time, but
may not be important to track five years from now. A decision will have to
be made as to what data should be tracked, and what data should not be
tracked. Also, this alternative may require several new data files and a
more complex linkage to current PCS files. Estimates for the necessary
contractor resources are from 12 to 18 man-months or $90,000 to $135,000,
and for EPA .personnel resources, from 3 to 4 man-months or $9200 to
$12,300.
Alternative 4 will have even higher personnel costs. In addition to
the PCI and Program Audit data, this alternative will track a limited
amount of Industrial User data. The ID data will be tracked using modified
PCS software. Current PCS programs will be adapted to track Industrial
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11-16
User data, at a substantially lower cost than creating a whole new system.
Alternative 4 will track those Industrial User data elements that are
analogous to elements currently in PCS. However, some changes to current
data element definitions may be necessary to adapt the system for Ills.
Estimated contractor resources for Alternative 4 are from 23 to 37
man-months or $172,500 to $277,500. Estimated EPA personnel resources are
8 to 10 man-months or $24,700 to $30,800.
Alternative 5 will most probably have the highest personnel costs. It
would be a large, complex system designed to track a full range of Control.
Authority and Industrial User data. The Industrial User capabilities will
require a substantial amount of preliminary study before they could be
implemented. Estimated contractor resources for Alternative 5 are from 72
to 108 man-months or $540,000 to $810,000. Estimated EPA personnel
resources are 20 to 28 man-months or $61,700 to $86,300.
Timesharing costs will be the on-line and batch processing computer
costs associated with the design and implementation of the system. These
costs also include any telecommunications costs associated with connecting
to the NCC computers. These costs were estimated by comparing the PPETS
alternatives with the average computer time expended during PCS
development. Monthly timesharing costs were estimated taking into account
the number of people working on development and the complexity of the new
system compared to PCS. This number was then multiplied by the estimated
implementation time (calculated as 2/3 of the total design and
implementation time estimated under 'Timeline Criteria') for each
alternative.
It is assumed that Alternative 2, being a small system, will have
relatively small timesharing development costs. Average monthly computer
time cost is estimated at $7200, for a total timesharing development cost
between $14iOOO and $19,000. Alternative 3, being a larger system is
estimated to have an average monthly computer time cost of $15,000, for a
total timesharing development cost of $40,000 to $70,000. Alternative 4 is
significantly, more complex than Alternative 3 and is estimated to have a
monthly average computer cost of $20,000, or a total timesharing
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11-17
development cost of $107,000 to $133,000. Alternative 5 is comparable in
size and complexity to PCS, and is estimated to have a monthly average
computer time cost of $45,000, for a total timesharing cost of $450,000 to
$540,000.
Travel costs are mostly for training purposes after the system has been
installed. Per diem costs are estimated at $75; long distance trans-
portation is estimated at $400 per trip; shorter distance transportation is
estimated at '$200 per trip.
Since Alternative 2 will be used only by National and Regional Office
personnel, there would only be a need for one centralized training session.
Total per diem expense: $1500; transportation expense: $4000. Total travel
expense: $5500.
Alternative 3 is designed for use by National Office, Regional Office,
and Approval Authority personnel. Therefore, it is estimated that 3
training sessions may be required. Estimated project team per diem
expense: $450; transportation expense: $2400. Estimated Regional trainee
per diem expense: $1050; transportation expense: $1400. Total travel
expense: $5300. No estimate was made for state travel expenses.
Alternatives 4 and 5 are designed to encourage the delegated State
Approval Authorities to participate in the system. Assuming that this
would be successful, these alternatives may require training sessions to be
held in each region. Estimated project team per diem expenses are: $3000;
transportation expense (assuming shorter distance travel): $4000. Total
project team travel expense: $7000. These alternatives would not require
regional travel, as the regions would be host sites. No estimate was made
for state travel expenses.
All the- alternatives are expected to have only modest hardware
requirements. All of them will be implemented on the EPA IBM Mainframe, so
there should be no new purchases of computers. The only equipment
purchases that may be necessary would be additional terminals (and modems
for some states) for Regional Offices and Approval Authorities, depending
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11-18
upon load requirements. It is assumed that any terminals purchased would
be IBM 3270's at a cost of $1200 each, and that no single office will have
to purchase more than 1 new terminal. The number of offices that will have
to purchase terminals will probably be related to the complexity of the
system and to the number of POTWs in each jurisdiction.
Alternative 2 is a fairly small, simple system, so only those regions
with more than 200 POTWs will probably have to purchase terminals: 2 new
terminals will cost $2400. The estimates for Alternatives 3, 4, and 5
assume that the EPA Regions will have to enter all of the data; if State
Approval Authorities decide to participate, this will reduce the need for
new terminals at EPA. Alternative 3, being more complex than Alternative
2, may require purchases of terminals in regions with more than 100 POTWs:
5 new terminals will cost $6000. Alternative 4 is a moderately large
system and may require purchases in regions with more than 50 POTWs and in
EPA Headquarters: 9 new terminals will cost $10,800. Alternative 5 is a
very large and complex system and will probably require an additional
terminal in each region and at EPA Headquarters: 11 new terminals will
cost $13,200.
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11-19
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11-20
2. Operating Cost Criteria
Operating cost criteria consist of those costs EPA can expect each year
in order to operate, maintain, and support the PPETS system. These costs
include:
• Data entry costs, including the EPA staff or contractor costs
to load new data into PPETS each year
• Equipment reliability and expected maintenance costs for
equipment not operated by NCC
• Operations and software maintenance costs, including the
contractor costs required to monitor updates to the system
and make programming adjustments and small enhancements
• Timesharing costs, including the connect time, processing
time, and telecommunications costs for PPETS data entry,
operations, retrievals, and maintenance
• User support costs, including the EPA staff costs required to
answer user questions and resolve problems
Dollar figures have been estimated for the annual operating cost
criteria expected to be incurred after the initial year of system
operations. Due to additional learning and shake-down costs, the first
year's operating expenses are estimated to be 30% greater than for
subsequent years. The only exceptions to this are equipment maintenance
costs, which are expected to be constant during the initial and subsequent
years of operation. These criteria and estimates are summarized for each
alternative in Exhibit II-6.
Data entry costs refer to those costs associated with loading new
pretre'atment data into PPETS each year. This data can be entered either by
manually typing on a terminal or by running a converter program which will
enter data into PPETS directly from a regional or state system. The
following estimates are calculated in contractor man-months and dollars.
Contractor costs for data entry are assumed to be $4000 per man-month,
which includes salary, overhead costs, general and administrative costs,
fee, and miscellaneous other direct costs. These estimates assume that the
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11-21
EPA Regions will have to manually enter all of the required data; if State
Approval Authorities decide to participate in Alternatives 3, 4, or 5, then
the data entry costs for EPA will be lower.
Alternative 1 has the smallest data entry costs as only a very limited
amount of pretreatment data is currently tracked. It is estimated that the
pretreatment data currently entered into PCS costs 0.1 man-month per Region
per year, or a total for all Regions of $4000 per year.
Alternative 2 will have a relatively small data entry cost. Only 1
record (about 45 data elements) will have to be entered for each POTW every
year. No Regional Office is responsible for more than 406 POTWs, so the
associated personnel cost should be small: from 0.75 to 1 man-month per
Region per year, or a total for all Regions of $30,000 to $40,000 per year.
Alternative 3 will have a greater data entry cost. In addition to the
Pretreatment Performance Summary data, data from about 292 Program Audits
and 1169 PCIs will have to be entered annually. It is not known at this
time just how much data from the PCI and Audit checklists will be entered,
but personnel costs are not expected to be more than 1 or 2 man-months per
Region per year, or a total for all Regions of $40,000 to $80,000 per year.
For Alternative 4, data could be entered from Pretreatment Performance
Summaries, PCIs, Program Audits, and data from about 1500 Categorical
Industrial Users'. It is not known just how much data will be tracked for
each IU, but a cost estimate would be from 2 to 3 man-months per year for
each Region, or a total for all Regions of $80,000 to $120,000 per year.
Alternative 5 will be the most expensive and could have potentially
very large data entry costs. It is not known at this time, how many
Industrial Users nor how much data States will want to track, but a cost
estimate would be from 9 to 11 man-months per year for each Region, or a
total for all Regions of $360,000 to $440,000 per year.
Equipment reliability and maintenance costs are not expected to be very
important for any of the alternatives. The most important equipment, the
-------
11-22
IBM mainframe, is maintained by NCC. The EPA Headquarters, Regional
Offices, and Approval Authorities will only have to maintain terminals,
modems, and printers. These are for the most part reliable and will
probably not require very much maintenance in the first five years of use.
It is estimated that the annual maintenance costs will be 10% of the price
of all equipment purchased for PPETS. It is assumed that this cost will be
constant for the initial and subsequent operating years. For Alternative
1, the equipment maintenance cost for the pretreatment data entered into
PCS is so sriiall that it is negligible. The equipment maintenance cost for
Alternative 2 will probably only be $200 annually; for Alternative 3, $600;
for Alternative 4, $1100; and for Alternative 5, $1300.
Operations and software maintenance includes monitoring system updates
and making adjustments and small modifications to PPETS software. The
following estimates are in contractor man-months and dollars. It is
assumed that contractor costs are $7500 per man-month, which includes
salary, overhead .costs, general and administrative costs, fee, and
miscellaneous other direct costs. The following estimates include only
minor modifications to PPETS. Major enhancements will probably cost more.
Alternative 1 tracks very little pretreatment data and requires very
little maintenance. It is estimated that the pretreatment data in PCS
currently requires only 0.25 man-month of software maintenance per year or
$1900 per year.
Alternative 2, being a small, straightforward system will probably
require little maintenance. Also, since Alternative 2 is a very modular
system, any enhancements that are required will probably be relatively
inexpensive to make. Estimated annual cost for software maintenance: 1
man-month or $7500. Alternative 3, being larger than Alternative 2, will
probably require more software maintenance. Estimated software maintenance
cost for Alternative 3: 3 man-months or $23,000.
Alternatives 4 and 5 will probably require significant software
maintenance. In Alternative 4, Industrial User data will be tracked on
modified PCS software. As the system is used, new ideas will probably
-------
11-23
develop about how to adapt even more IU data to PCS software. Estimated
software maintenance cost for Alternative 4: 6 man-months or $45,000.
Alternative 5 will be a large, complex system and will probably require
software maintenance, at least during its first few years as the system
becomes more streamlined. Estimated software maintenance cost for
Alternative 5: 12 man-months or $90,000.
Timesharing costs are all the computer time costs associated with data
entry, retrieval, operation, and maintenance of the PPETS system. These
costs include connect time, processing time, data storage, and
telecommunications. The following figures are based on current PCS
timesharing costs, and were estimated by comparing the size and complexity
of PCS to the different alternatives. Alternative 1 contains very little
pretreatment data, and its portion of PCS timesharing costs is only about
$6000 per year. Alternative 2 is estimated to have a timesharing cost of
$24,000 to $60,000 per year. Alternative 3 is estimated to have a
timesharing cost of $96,000 to $120,000 per year. Alternative 4 is
estimated to have a timesharing cost of $180,000 to $240,000 per year.
Alternative 5 is estimated to have a timesharing cost of $996,000 to
$1,200,000 per year.
User support costs will vary significantly between alternatives.
Currently, EPA devotes 10 man-days each week for user support and handles
about 100 calls per week. The following estimates assume that user support
staff are EPA personnel at GS 13, step 1, with a salary of $37,000 per
year. Alternative 1 requires very little user support, and its share of
current PCS user support resources is probably only 0.2 man-day per week,
or $1500 per year. Each of the other proposed systems will probably
increase the present demand and cost for user support. Alternative 2,
being a. small . system, will probably require only modest user support,
perhaps only 1 additional man-day per week or $7400 per year. Alternative
3, being a somewhat larger system, will probably require more user support,
perhaps 2 additional man-days per week or $14,800 per year. Alternative 4
is a moderately large and complex system and may require 4 additional
man-days per week for user support or $29,600 per year. Alternative 5,
being a very large system, will require a significant increase in user
support, perhaps from 5 to 10 additional man-days per week, or from $37,000
to $74,000 per year.
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11-25
E. Technical Criteria
Technical Criteria address data processing technical issues such as:
t System/data security and integrity
• System availability and reliability
• Capability to interface with high level languages
t Simplicity of operation
• Ability to recover from system failures
• Amenability to quick and accurate resolution of problems
• Transaction auditability
A summary of these criteria for all alternatives is contained in
Exhibit II-7. Because all the proposed alternatives would be programmed on
the EPA IBM Mainframe and implemented as an expansion of PCS, most of these
criteria will be similar for all alternatives.
The security and integrity of the PCS system and data is currently very
good. There are security measures built into the PCS software to prevent
unauthorized access. Data being entered into PCS goes through edit checks
to ensure its integrity. Although security was not a priority for PPETS,
all the alternatives, being expansions of PCS, will be subject to the same
security protections. The only exception may be the Industrial User data
in Alternative 5, which as a separate system, could be designed with any
desired level of security.
The availability and reliability of the PCS system and IBM mainframe is
good at the present time. The mainframe is usually available, although
response time sometimes slows in the early afternoon. The IBM mainframe Is
down only one hour per month for routine maintenance. Overall the system
is up 95%-of the time. None of the alternatives is expected to adversely
affect this record.
Because of security constraints, high level languages can only be run
indirectly on PCS. Users must first run a special utility function that
-------
11-26
creates a separate data file and obeys the security constraints for data
access. Users can then run high level languages, like SAS and FOCUS, on
this separate data file. To maintain the security of the PCS data, all of
the alternatives should follow the same pattern for access.
The new PPETS system is expected to be designed for simplicity of
operation and user-friendliness. It is hoped that those already using PCS
will need little training to use PPETS, and that new users will have no
difficulties learning and using the system.
System failures for the IBM mainframe and PCS are infrequent. Recovery
is usually very quick and sometimes almost immediate. The recovery rate is
considered very good and none of the alternatives should have adverse
effects in this area.
EPA currently provides user support for PCS to answer questions and
resolve problems. At present, they receive an average of about 100 calls
per week. Most of these are for questions and minor difficulties; however,
a few calls each week are for major problems. Some of these problems can
take from one to two weeks to fully investigate and correct, or from two
days to a week if the problem is urgent. Alternatives 2 and 3 are much
smaller and simpler than the full PCS system, so problems should take no
longer than a few days to resolve. Alternative 4 is somewhat more complex
and extensive than 2 or 3, so large problems may take about a week to
resolve. Alternative 5 may be similar in complexity to PCS, so problems
with that system will probably take one to two weeks to resolve.
Transaction auditability refers to tracing system usage. It records
who entered, changed, and deleted various data and when. This information
is useful when determining the frequency of system updates and when
investigating system problems. Under the current system, one has to
request thTs historical data from the PCS user support staff. All of the
PPETS alternatives will probably have similar procedures for transaction
auditability—the data will be there if necessary, but it will be somewhat
difficult to access.
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11-28
F. Timeline Criteria
Timeline criteria deals with issues related to the time it will take to
complete basic tasks for developing the system. Four major timeline
criteria have been defined:
• Preliminary studies timeline, including the time required to
determine the precise information and access requirements and
the specific data elements to be tracked
• Design and implementation timeline, including the time
required to plan, develop, test, and document all the new
PPETS software and modifications to PCS
• NCC approval timeline, including the time it will take the
NCC to review, comment, and approve the new PPETS system
and/or modifications to PCS
• Training and installation timeline, including the time
required to set up, introduce, and teach PPETS to all of its
expected users
The time periods for these tasks will vary greatly between each
alternative. Exhibit II-8 contains a summary of the timeline estimates for
each of the options. Alternative 1, being the current system, will
naturally have no timeline considerations in any of the categories. Time
frames have been estimated for each of the other alternatives. These
estimates are intended to serve as a comparison for the different options.
In general, the,more complex a system is, the longer its development time
will be.
Preliminary Studies are one of the most important tasks to be
conducted. They ensure that the system being developed will actually fill
the needs of the intended users. Alternative 2 will require a relatively
small amount of preliminary study. It is a small, straightforward system.
Its data elements have already been defined by EPA in the suggested format
for Control Authority Pretreatment Performance Summaries in the
Pretreatment Compliance Monitoring and Enforcement Guidance. Actual design
and implementation could start soon after completion of the feasibility
study. Estimated time for preliminary studies for Alternative 2: 1 to 2
-------
11-29
months.
Alternative 3 is more complex than Alternative 2 and will require more
preliminary work. In addition to the Pretreatment Performance Summaries,
Alternative 3 also contains data on PCIs and Program Audits. Although EPA
has published suggested formats for PCI and Program Audit checklists, these
are too extensive to be entirely entered into PPETS. EPA will have to
determine what checklist data should be tracked by PPETS and what should
not be tracked. Estimated time for preliminary studies for Alternative 3:
2 to 4 months.
In addition to all the data in Alternative 3, Alternative 4 also tracks
limited amounts of Industrial User data. There are currently some IU
reports for which EPA has not issued suggested formats. Although the
Industrial User data will be tracked using modified PCS software, some
study will be needed to determine precisely what IU data can be tracked and
to standardize the necessary reports. Estimated time for preliminary
studies for Alternative 4: 3 to 5 months.
Alternative 5 will contain PPS, PCI, and Program Audit data and will
also track a full range of Industrial User data. A substantial preliminary
study would have to be conducted to determine what data should be tracked
for both categorical and noncategorical lUs. The study would have to
include the EPA Headquarters, Regional Offices, Approval Authorities, and
perhaps even some Control Authorities. This could be a long and perhaps
costly process. Estimated time for preliminary studies for Alternative 5:
6 to 8 months.
Actual design and implementation of the system will be the other major
time cost. Alternative 2 is a small system. It will be implemented as a
separate data file to PCS and will probably be fairly modular and easy to
design. Estimated time for design and implementation of Alternative 2: 3
to 4 months.
Alternative 3 is a moderately sized system. It will involve adding
several new data files and may include some potentially complex linkages
-------
H-30
and expansions of current PCS files. Estimated time for design and
implementation of Alternative 3: 4 to 7 months.
Alternative 4 will incorporate all the design and implementation work
of Alternative 3. It will also involve the modification of current PCS
software to permit the tracking of IU data. This will probably take
considerably less time than creating a whole new system for Industrial User
data. Estimated time for design and implementation of Alternative 4: 8 to
10 months.
Alternative 5 is a large, complex system. There is a very large range
of Industrial User data for the system to track. It will probably take
considerable time to design, Implement, and test. Estimated time for
design and implementation of Alternative 5: 15 to 18 months.
NCC procedures and required approval will also add some time delay to
each of the proposed systems. Alternative 2, being a fairly straight-
forward enhancement to PCS, should be approved by NCC quickly, probably
within 1 week. Alternative 3 is a substantially larger enhancement to PCS,
and NCC will probably require more time to examine the system; approval may
take 1 month. If Alternative 4 is considered an enhancement, instead of a
new system, then NCC approval should again take about 1 month. Since
Alternative 5 is a large new system, it will require NCC approval at
several design steps. These NCC approvals could take about 3 months all
together; however, some development work could probably be performed
concurrently with the approval process, so the overall -delay should only be
about 2 months.
Proper training and installation is necessary for the success of the
system. Alternatives 2 and 3 are both relatively small systems. They can
both probably be installed quickly and training for all users can occur at
the same time. Estimated time for training and installation of
Alternatives 2 and 3: 1 month.
Alternative 4 is a more complex system than 2 or 3. It may be better,
in this case, to phase in the ..installation and training over a period of
-------
11-31
time in order to correct any problems or make suggested improvements to the
system. Estimated time for training and installation of Alternative 4: 2
to 4 months.
Alternative 5 is a large and complex system. Some modifications and
adjustments will most probably need to be made initially. The system may
have significant impacts on Approval Authority operations. Installation
and training should be phased in over time. Estimated time for training
and installation of Alternative 5: 4 to 8 months.
The overall time frames for Alternatives 2, 3, 4, and 5 vary
significantly. Total timeline estimates are: Alternative 2, from 5 to 7
months; Alternative 3, from 8 to 13 months; Alternative 4, from 14 to 20
months; and Alternative 5, from 27 to 36 months.
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11-33
G. Change Potential Criteria
Change potential includes how modifiable the PPETS system will be to
new technologies and new data and applications requirements. Basic
criteria are:
• Ability to handle varying transactions loads
• Ability to adapt to new technologies
• Ability to increase or reduce the number of data elements tracked
• Ability to integrate new applications and programs
• Ability to store substantially greater volumes of data
A summary of these criteria for all alternatives can be found in
Exhibit II-9. Because all of the alternatives would be implemented in PCS,
they will all have fairly similar change potentials.
The ability to handle varying transaction loads does not appear to be a
significant problem at this time. PCS and the IBM mainframe seem to have
enough capacity to handle most transaction loads. However, according to
EPA sources, the system does sometimes get a little slow during prime
computing time (between 12:00 and 2:00 pm), but is fine during the rest of
the day. Some large-scale PCS data retrievals tend to be somewhat slow,
but this is due more to the large volumes of data in PCS than to
transaction loads. The more complex options, Alternatives 4 and 5, will
probably have the highest transaction loads and could conceivably have an
adverse impact on mainframe systems, although this is not considered to be
likely.
The ability to adapt to new technologies will depend a great deal upon
NCC and the enhancements that they make on their computers. New data base
environments* high level user languages, processing capability improve-
ments, hardware, telecommunication lines, etc. depend upon NCC decisions.
Of course, the EPA Headquarters, Regional Offices, and Approval Authorities
can always connect new peripherals (terminals and printers) to the system.
-------
11-34
The ability to increase or reduce the number of required data elements
will be a significant factor in different alternatives. In general, it is
not very difficult to make small increases (i.e. only a few data elements)
to the PCS data base. Alternative 2, which can be implemented as a small
separate PCS data file, will probably be especially modular and very easy
to modify. However, Alternatives 3, 4, and 5 may be a little more
difficult to change. They are more elaborate systems and further
enhancements may involve changes to several PCS files.
Alternative 2 will also probably not require many modifications. The
data contained in the Pretreatment Performance Summaries is very basic and
limited, and may not have to be changed very often. Alternatives 3, 4, and
5, on the other hand, will contain PCI and Program Audit data. It appears
likely that as the National Pretreatment Program develops, PCI and Program
Audit procedures and checklists will probably change significantly over
time. Although PCS is flexible, it may not be flexible enough to keep up
with PCI and Program Audit evolution.
PCS and its ADABAS implementation appear to be very flexible when it
comes to new applications. The ability to integrate new applications and
programs is not expected to be a problem with any of the alternatives.
The ability to store substantially greater volumes of data, however,
may present a problem for PCS. Modifying any of the alternatives to accept
substantially more data will probably require a significant expenditure of
resources. PCS is flexible as was proved by the addition of evidentiary
hearing and grant information data, and as PPETS will again prove.
Nevertheless, a substantial increase to the PCS data base, requires
substantial effort.
-------
CHANGE POTENTIAL CRITERIA
Alternative 1:
No National
Automated
System for
Pretreatment
Enforcement
Tracking
Alternative 2:
EPA Oversight
System
(Headquarters
and Regions}
Alternative 3:
im for
notifies
and Higher
Levels
Alternative 4:
System for
Approval
Authorities and
Higher Levels
(with Limited
IU
Alternative 5:
System for
Approval
Authorities
and Higher
Levels (with
Extensive
III Data)
Ability to Handle
Varying Transaction
Loads
Ability to Adapt to
New Technologies
Ability to Increase or
Reduce Number of
Data Elements
Ability to Integrate New
Applications and
Programs
11-35
Ability to Store
Substantially Greater
Volumes of Data
PCS transaction load is
not usually a problem.
However, the mainframe
does sometimes get a
liflte slow between
12:00 and 2:00 PM,
Large scale data
retrievals do take awhile.
but this is due to the
amount of data, not
transaction bad.
Alternative 2 is a small
system and will probably
have a limited amount of
data to be entered and
retrieved at any given
time. Therefore, trans-
action loads are expected
to be moderate and steady
and should pose no
problems.
Alternative 3, being a
larger system, will
probably have a little more
variation in data entry and
retrieval loads. This
probably wont cause any
problems as long as the
IBM mainframe is not
overloaded.
In addition to the data in
Alternative 3, Alternative
4 will contain data on an
estimated 1, 500 (Us. This
will cause a higher toad
variation which may cause
some problems if the
number of (Us tracked
turns out to be actually
much higher.
Alternative 5, being a
rather large system,
will probably have a
highly variable transaction
load. Its see and any
potential problems are
difficult to estimate since
it is not known how many
Approval Authorities • -
would participate and how
much IU data would be
tracked.
The technology of PCS
and the mainframe
systems depend to a
large extent upon tCC
decisions. New
peripherals (printers,
terminals), however,
could be added at
anytime.
The technology of PCS
and the mainframe
systems depends to a
large extent upon NCC
decisions. New
peripherals (printers,
terminals), however,
could be added at
anytime.
The technology of PCS
and the mainframe
systems depends to a
large extent upon NCC
decisions. New
peripherals (printers,
terminals), however.
could be added at
anytime.
The technology of PCS
and the mainframe
systems depends to a
lapMn nuldMt 1 ww«l tkjf*"f*
large extent upon OK/O
decisions. New
peripherals (printers,
terminals), however,
could be added at
anytime.
The technology of all
mainframe systems
depends to a targe
extent upon NCC
decisions. New
peripherals (printers,
terminals), however,
could be added at
anytime.
Small increases and
decreases to the data
base (i.e., one or two
new data elements)
pose very little problem
for PCS.
Being a small system,
with very basic data,
Alternative 2 probably
would not require very
many changes. Since it
is implemented in a
separate PCS data file,
data modifications would
be fairly easy to make.
PCIs and Program Audits
can have somewhat
extensive data, and it
seems probable that
they wiS change and
evolve over the next
several years. Although
PCS is flexible, it may
not be able to keep up
with format and data
chanpes.
PCIs and Program Audits
can have somewhat
extensive data, and it
seems probable that
they wil change and
evolve over the next
several years. Although
PCS is flexible, it may
not be able to keep up
with format and data
changes.
PCIs and Program Audits
can have somewhat
extensive data, and it
seems probable that
they wil change and
evolve over the next
several years. Although
an ADABAS system is
flexible, it may not be
able to keep up with
format and data changes.
New applications and
programs should pose
no particularly large
problem for PCS or
its ADABAS
implementation.
NewappBcationsand
programs should pose
no particularly large
problem for PCS or
its ADABAS
implementation.
New appficafions and
programs should pose
no particularly large
problem for PCS or
its ADABAS
implementation.
New applications and
programs should pose
no particularly large
problem for PCS or
its ADABAS
implementation.
New applications and
programs should pose
no particularly large
problem tor PCS or
the proposed IU data
system.
A substantially larger
data base will involve
major modifications to
PCS and may require
significant expenditures.
A substantially larger
data base will involve
major modifications to
PCS and may require
significant expenditures.
A substantially larger
data base will involve
major modifications to
PCS and may require
significant expenditures.
A substantially larger
data base will involve
major modifications to
PCS and may require
significant expenditures.
A substantially larger
data base will involve
major modifications to
the tracking system
software and may
require significant
expenditures. .
EXHIBIT II-9
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11-36
H. Organizational Impact Criteria
Organizational impact criteria refer to the effects that a new PPETS
system will have on relevant EPA organizations. Exhibit 11-10 summarizes
the effects the different alternatives will have on the EPA Headquarters,
Regional Offices, and Approval Authorities. The criteria considered
include:
• Requirements to add staff or to obtain new skills
• Reorganization of day-to-day operations
• Changes in reporting relationships
Obviously, Alternative 1 requires almost no changes to EPA
organizations. However, even under the status quo, a greater consistency
of data measurements and formats is regarded as desirable, and changes in
current reporting relationships have been proposed. Guidances have been
issued with suggested formats for Pretreatment Compliance Inspections,
Pretreatment Program Audits, and Control Authority Annual Reports and
Pretreatment Performance Summaries.
Each of the other alternatives will require certain staff additions.
These staff additions can either be contractor" staff or EPA staff,
depending upon budget conditions. Alternative 2 will probably require the
least additional' personnel resources, as it is a small system mainly
serving the National and Regional Offices. Regions IV and V may find it
necessary to increase their staffs as they are responsible for the most
POTWs and will have to enter about 391 and 290 PPSs respectively each year.
However, the staff additions should not be more than one part-time employee
for those regions.
Alternatives 3, 4, and 5 will probably require some additional staff in
the Approval Authorities. The amount of staff resources required will
depend upon how many States decide to participate in PPETS. The Regional
Offices will have to enter' data for those States that decide not to
participate. Also, Alternative 5 will probably require greater staff
-------
11-37
resources than the others since it will have significantly more data to be
entered and more data that will be retrieved and analyzed.
Training will be required for all the proposed systems. Alternative 2
will require training only in the National and Regional Offices, while
Alternatives 3, 4, and 5 will require training in the National Office,
Regional Offices, and Approval Authorities. Also, Alternatives 2, 3, 4,
and 5 will require progressively more training respectively, as the systems
are more complex.
The reorganization of day-to-day operations is difficult to assess.
Alternative 2 will probably have a minimal impact on day-to-day operations.
Alternatives 3 and 4 may have some effects on those Approval Authorities
that decide to participate. Data from PCIs and Audits will have to be
entered and will be easier to track and analyze. Alternative 4 will help
Approval Authorities track those Industrial Users for which they also act
as Control Authorities.
Alternative 5 may have a significant impact on the participating
Approval Authorities. Depending upon the amount of Industrial User data
the Approval Authority decides to enter, there may be sizable impact on
data entry resources and a significant enhancement of the Authority's
ability to supervise and regulate POTW operations and IU pretreatment
compliance.
All of the alternatives will require changes in current reporting
relationships. Recently, EPA has been issuing suggested formats for
different reports. Under Alternative 2, the information contained in the
Control Authority Pretreatment Performance Summaries (to be included with
Annual Reports) will have to be made mandatory and their data fields
standardized according to the EPA Pretreatment Compliance Monitoring and
Enforcement ' Guidance. Alternatives 3, 4, and 5 will require not only
Pretreatment Performance Summaries be standardized, but also certain data
from PCI and Program Audit checklists be made mandatory. Alternatives 4
and 5 will also require that some format be established for Industrial User
reporting data and inspections by POTWs.
-------
11-38
However, no new reports will be required under any of the alternatives;
only current and already proposed reports would have to be standardized.
PPETS will not change any basic relationships between EPA organizational
levels, but it will help EPA Headquarters, Regional, and Approval Authority
offices with their oversight roles. PPETS may also facilitate the
submission of reports to EPA Headquarters and Regional Offices, since this
could now be done electronically.
-------
11-39
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III-l
III. CONCLUSIONS AND RECOMMENDATION
Under the National Pretreatment Program, EPA is required to implement
nationwide regulations controlling the pollutants discharged to Publicly Owned
Treatment Works (POTWs) by Industrial Users. To adequately fulfill this
function, EPA has definite needs for pretreatment permits and enforcement
data.
It is clear from the Tracking System Objectives Chart (Exhibit II-l) that
the current system, or Alternative 1, does not meet most of EPA's data needs.
For pretreatment tracking, the current PCS system only gives very general data
about the occurrence and dates of PCIs and Program Audits. Although
important, this information is not sufficient to help implement or assess the
effectiveness of the NPP. More data is definitely needed.
Alternative 2 provides considerably more information than is currently
available to the EPA Headquarters and Regional Offices. It fully supports two
of the most important objectives listed in the Summary of Pretreatment
Tracking Needs: (1) To determine the overall effectiveness of the national
program; and (2) To evaluate EPA regional oversight effectiveness. In
addition, Alternative 2 partially supports many of the other tracking system
objectives. Although it doesn't provide complete information, Alternative 2
will provide enough data to point out problem areas in pretreatment
enforcement. Further investigation, such as examining PCIs and Program Audits
or conducting field visits, could then be undertaken. . Alternative 2 would
significantly improve EPA's ability to pinpoint troubled municipalities and
allocate its efforts accordingly. In addition, Alternative 2 is a small,
well-defined system. It could be implemented in a relatively short time frame
of 5 to 7 months, and at a cost of $55,000 to $78,000, less than half of the
cost of any of the other proposed new systems. Its five year operating costs
would be from $366,000 to $610,000.
Alternative 3 provides considerably fuller coverage than Alternative 2.
It fully supports many of the tracking system objectives that Alternative 2
can only partially support. However, its data is not as well defined. EPA
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III-2
has recently Issued extensive PCI and Program Audit checklists. These
checklists contain a variety of data, only some of which should be entered
into PPETS. EPA would have to come to a consensus about precisely which data
should be included. Alternative 3 could be implemented within 8 to 13 months,
at a cost of $151,000 to $229,000. Its five year operating costs would be
from $923,000 to $1,262,000.
Alternative 4 fills most of EPAs tracking needs and provides significant
help to Approval Authorities which have assumed Control Authority functions.
Since its Industrial User data will be tracked using only modified PCS
software, the additional programming costs should not be too great. However,
preliminary study will be required to determine which Industrial User data
elements can be tracked by PCS software. Some IU data will be analogous to
current PCS elements, but some may be difficult to track, such as production
based effluent limits. EPA has already issued guidances for Pretreatment
Performance Summaries, PCI checklists, and Program Audit checklists, but has
not issued similar suggested formats for many Industrial User reports, except
monitoring reports. Format requirements may have to. be developed for some
Categorical IU reports in areas where the Approval Authority also acts as
Control Authority. Estimates for the development of Alternative 4 are from 14
to 20 months, at a cost of $322,000 to $459,000. Its five year operating
costs would be from $1,780,000 to $2,310,000.
Alternative 5 is a large and complete system. Given sufficient Industrial
User data, it could satisfy all of the EPA tracking system objectives.
However, it will cost significantly more than all the other alternatives.
Estimates are for a 2 to 3 year project at a cost of 1.1 to 1.5 million
dollars. Its five year operating costs would be from $7,865,000 to
$9,567,000. Although a comprehensive system, like Alternative 5, may be
desirable in the future, at this time of budget constraints, it is probably
too expensive.
Regardless of which alternative is chosen, EPA will have to make some of
its suggested reports mandatory. An automated system needs to have
standardized data in standardized formats. If not, the data entry may become
very expensive and the data itself may be inconsistent.
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III-3
From the analyses conducted, there appears to be a clear need for a new
Pretreatment Permits and Enforcement Tracking System. Alternative 4 seems to
be the best choice to fully satisfy many of EPA's information needs, without
going to the expense of a comprehensive system, like Alternative 5.
Alternative 4 will provide substantial information about POTWs and their
pretreatment permits and compliance efforts, and also provide specific data
about a limited subset of Industrial Users.
Instead of" being implemented all at one time, Alternative 4 should be
implemented in a two step approach:
• Step 1: Implementation of the PPETS system to track PCI,
Program Audit, and PPS data (Alternative 3).
• Step 2: Enhancement of the PPETS system to track the limited
amounts of Industrial User data (Alternative 4).
This incremental approach will have a pretreatment system on-line within a
shorter period of time and will not require any duplication of effort.
Although Step 1 is to be developed as a package, use and data entry to the
system should be phased in over time. As the EPA Regions and Approved States
implement and develop their pretreatment programs, usage of the PPETS system
should be increased. It is suggested that PPETS be first utilized to track
PCI and Program Audit data. Currently, much of EPA's pretreatment efforts are
directed towards PCIs and Program Audits, which provide the most comprehensive
and accurate data about POTW operations. Data from Pretreatment Performance
Summaries would be incorporated into PPETS as the second phase of Step 1.
After the Step 1 PPETS system is operational, the Step 2 system should be
developed. This will give PPETS the full Alternative 4 capabilities.
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A-l
APPENDIX A:
Data Contained In Alternative 1
Source: Pretreatment Compliance Inspections and Program Audits
t Counts of PCIs and Program Audits
— POTW Where PCI or Audit Took Place
Type of Inspection (PCI or Program Audit)
Date of Inspection
Approved Pretreatment Program Indicator
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A-2
Data to be Contained In Alternative 2
Source: PCI and Program Audit Data Currently in PCS
• Counts of PCIs and Program Audits
POTW Where PCI or Audit Took Place
Type of Inspection (PCI or Program Audit)
Date of Inspection
Approved Pretreatment Program Indicator
Source: POTW Pretreatment Performance Summary
Alternative 2 will contain all of the data in the EPA guidance
suggested format for Pretreatment Performance Summaries, including:
• Geographic Information About POTWs and Counts of Ills
— NPOES Number
Name, Address, Contact Person, Telephone Number, etc.
(Some of this data may be referenced from other PCS files and
not duplicated here.)
Total Number of Categorical Ills
Total Number of Noncategorical ILJs
Reporting Period
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users, except where noted)
No. of SIUs Submitting BMRs/No. Required (Categorical Only)
No. of SIUs Submitting 90-day Compliance Reports/No. Required
(Categorical Only)
No. of SIUs Submitting Semi-Annual Report/No. Required
No. of SIUs Meeting Compliance Schedule/No. Required to Meet
Schedule
No. of SIUs in Significant Noncompliance/Total No. of SIUs
Rate of Significant Noncompliance for all SIUs (Categorical
and Noncategorical Combined)
• Compliance Monitoring Program Data (Summary level data would
include separate listings for categorical and noncategorical
users)
."— No. of Non-Sampling Inspections Conducted
No..of Sampling Visits Conducted
No. of Facilities Inspected (Non-Sampling)
No. of Facilities Sampled
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A-3
Alternative 2 Contents, Continued:
• Enforcement Actions Data (Summary level data would include
separate listings for categorical and noncategorical users)
Compliance Schedules Issued/Schedules Required
Notices of Violations Issued to SIUs
Administrative Orders Issued to SIUs
— Civil Suits Filed
-- Criminal Suits Filed
Significant Violators
-- Was Significant Violators List Published
— Amount of Penalties Collected (Total Dollars/IU Assessed)
Other Actions (Sewer Bans, etc.)
-------
A-4
Data to be ContainedIn Alternative 3
Source: POTW Pretreatment Performance Summary
Alternative 3 will contain the same data from the Pretreatment
Performance Summaries as Alternative 2 including:
• Geographic Information About POTWs and Counts of lUs
— NPDES Number
Name, Address, Contact Person, Telephone Number, etc.
(Some of this data may be referenced from other PCS files and
not duplicated here.)
-- Total Number of Categorical lUs
Total Number of Noncategorical IDs
Reporting Period
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users, except where noted)
No. of SIUs Submitting BMRs/No. Required (Categorical Only)
No. of SIUs Submitting 90-Day Compliance Reports/No. Required
(Categorical Only)
No. of SIUs Submitting Semi-Annual Report/No. Required
No. of SIUs Meeting Compliance Schedule/No. Required to Meet
Schedule
No. of SIUs in Significant Noncorapliance/Total No. of SIUs
Rate of Significant Noncompliance for all SIUs (Categorical
and Noncategorical Combined)
t Compliance Monitoring Program Data (Summary level data would
include separate listings for categorical and noncategorical
users)
No. of Non-Sampling Inspections Conducted
No. of Sampling Visits Conducted
No. of Facilities Inspected (Non-Sampling)
No. of-Facilities Sampled
• Enforcement Actions Data (Summary level data would include
separate listings for categorical and noncategorical users)
Compliance Schedules Issued/Schedules Required
-- Notices of Violations Issued to.SIUs
Administrative Orders Issued to SIUs
— Civil Suits Filed
Criminal Suits Filed
Significant Violators
Was Significant Violators List Published
Amount of Penalties Collected (Total Dollars/IU Assessed)
Other Actions (Sewer Bans, etc.)
-------
A-5
Alternative 3 Contents, Continued:
Source: Pretreatment Compliance Inspections and Program Audits
Alternative 3 will contain data from the EPA guidance suggested formats
for PCI and Program Audit checklists, including:
• PCI / Audit Identification Data
— POTW NPDES Code
— Date of PCI or Audit
Name of Auditor(s) or Inspectors(s)
Control Authority Representative
• Control Authority Pretreatment Program Overview Data
Number of Categorical Industrial Users
Number of Significant Noncategorical Industrial Users
Number of Noncategorical Industrial Users
Local Definition of "Significant Industrial User"
Percentage of Total Wastewater Flow to POTW that is
Attributed to Industrial Users
Recent Changes to Control Authority Pretreatment Program
• Control Authority Inspection and Monitoring of Industrial Users
Indicators About the Frequency of Inspections of Categorical
and Significant Noncategorical lUs
Indicators About the Frequency of Control Authority Sampling
of Categorical and Significant Noncategorical lUs
Percentage of SIUs Not Inspected in the Past Year
Percentage of SIUs Not Sampled in the Past Year
Data About the Frequency of Sampling and Self-Monitoring
Reports Conducted by Categorical and Significant
Noncategorical lUs
• Count of SIUs Covered by a Control Mechanism
Number and Percentage of SIUs Covered by an Existing,
Unexpired Permit, Contract, or Other Control Mechanism.
Number and Percentage of Permits That Need to be Issued
• IU Compliance and Enforcement Actions Data (Summary level only)
Percentage of All lUs Which Needed to Install Pretreatment
Technologies and Have Done So.
Percentage of SIUs in Significant Noncompliance with
Applicable Pretreatment Standards
—. Percentage of SIUs in Significant Noncompliance with
Self-Monitoring Requirements
Percentage of SIUs in Significant Noncompliance with
Reporting Requirements
Percentage of SIUs Subject to Some Kind of Enforcement Action
During Past Year
t IU File Evaluation Data
Ranking or Code to Indicate the Adequacy and Any Major
Deficiencies in the POTW IU Files Examined
-------
Alternative 3 Contents, Continued:
A-6
Evaluation Comments of Inspector/Auditor (To Be Stored as a Set of
Ranking Codes)
Codes Ranking the POTW's Monitoring Program
Codes Ranking the POTW's Control Mechanisms
Codes Ranking IU Self-Monitoring Data and Reports
Codes Ranking Control Authority Enforcement Procedures
Codes Describing Other Findings
Codes Describing Suggested Follow Up Actions
Background Control Authority Data
There was a substantial amount of other data in the Program
Audit checklist that may be very useful for background data,
since it may not change significantly over time. EPA will
have to decide what data should be kept on-line for
background purposes.
-------
A-7
Data to be Contained in Alternative 4
Source: POTW Pretreatment Performance Summary
Alternative 4 will contain the same data from the Pretreatment
Performance Summaries as Alternative 2 including:
• Geographic Information About POTWs and Counts of lUs
— NPOES Number
Name, Address, Contact Person, Telephone Number, etc.
(Some of this data may be referenced from other PCS files and
not duplicated here.)
-- Total Number of Categorical lUs
Total 'Number of Noncategorical lUs
Reporting Period
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users, except where noted)
No. of SIUs Submitting BMRs/No. Required (Categorical Only)
No. of SIUs Submitting 90-Day Compliance Reports/No. Required
(Categorical Only)
No. of SIUs Submitting Semi-Annual Report/No. Required
No. of SIUs Meeting Compliance Schedule/No. Required to Meet
Schedule
No. of SIUs in Significant Noncompliance/Total No. of SIUs
Rate of Significant Noncompliance for all SIUs (Categorical
and Noncategorical Combined)
• Compliance Monitoring Program Data (Summary level data would
include separate listings for categorical and noncategorical
users)
. — No. of Non-Sampling Inspections Conducted
No. of Sampling Visits Conducted
No. of Facilities Inspected (Non-Sampling)
No. of-Facilities Sampled
• Enforcement Actions Data (Summary level data would include
separate listings for categorical and noncategorical users)
Compliance Schedules Issued/Schedules Required
— . Notices of Violations Issued to SIUs
Administrative Orders Issued to SIUs
-- Civil Suits Filed
— Criminal Suits Filed
Significant Violators
-- Was Significant Violators List Published
Amount of Penalties Collected (Total Dollars/IU Assessed)
Other Actions (Sewer Bans, etc.)
-------
A-8
Alternative 4 Contents, Continued:
Source: Pretreatment Compliance Inspections and Program Audits
Alternative 4 will contain the same data from Pretreatment Compliance
Inspections and Program Audits as Alternative 3, including summary data
concerning:
• PCI / Audit Identification Data
— POTW NPDES Code
Date of PCI or Audit
Name of Auditor(s) or Inspectors(s)
Control Authority Representative
• Control Authority Pretreatment Program Overview Data
Number of Categorical Industrial Users
Number of Significant Noncategorical Industrial Users
Number of Noncategorical Industrial Users
-- Local Definition of "Significant Industrial User"
Percentage of Total Wastewater Flow to POTW that is
Attributed to Industrial Users
Recent Changes to Control Authority Pretreatment Program
• Control Authority Inspection and Monitoring of Industrial Users
Indicators About the Frequency of Inspections of Categorical
and Significant Noncategorical lUs
Indicators About the Frequency of Control Authority Sampling
of Categorical and Significant Noncategorical lUs
Percentage of SIUs Not Inspected in the Past Year
Percentage of SIUs Not Sampled in the Past Year
Data About the Frequency of Sampling and Self-Monitoring
Reports Conducted by Categorical and Significant
Noncategorical lUs
• Count of SIUs Covered by a Control Mechanism
Number- and Percentage of SIUs Covered by an Existing,
Unexpired Permit, Contract, or Other Control Mechanism.
Number and Percentage of Permits That Need to be Issued
• IU Compliance and Enforcement Actions Data (Summary level only)
Percentage of All lUs Which Needed to Install Pretreatment
Technologies and Have Done So.
Percentage of SIUs in Significant Noncompliance with
Applicable Pretreatment Standards
Percentage of SIUs in Significant Noncompliance with
Self-Monitoring Requirements
Percentage of SIUs in Significant Noncompliance with
Reporting Requirements
Percentage of SIUs Subject to Some Kind of Enforcement Action
During Past Year
-------
A-9
Alternative 4 Contents, Continued:
• IU File Evaluation Data
Ranking or Code to Indicate the Adequacy and Any Major
Deficiencies in the POTW IU Files Examined
• Evaluation Comments of Inspector/Auditor (To Be Stored as a Set of
Ranking Codes)
Codes Ranking the POTW's Monitoring Program
Codes Ranking the POTW's Control Mechanisms
— Codes Ranking IU Self-Monitoring Data and Reports
Codes Ranking Control Authority Enforcement Procedures
Codes Describing Other Findings
Codes Describing Suggested Follow Up Actions
• Background Control Authority Data
There was a substantial amount of other data in the Program
Audit checklist that may be very useful for background data,
since it may not change significantly over time. EPA will
have to decide what data should be kept on-line for
background purposes.
Source: Various Industrial User Reports
In Alternative 4, Industrial User data will only be tracked for lUs
where the State or Regional Approval Authority also acts as the Control
Authority.
• General Industrial User Identification Data
Permit or Contract Number
Name of Industrial User
Contact Person
Telephone Number
— SIC Codes
• Sampling and Reporting Requirements
Required Sampling Frequency
Actual Sampling Frequency
Required Date of Report Submission
Actual Date of Report Submission
• "Pollutant Limits Data
-- Pollutant Parameters
Maximum Concentration and Quantity Limits
Minimum Concentration Limits
Average Concentration and Quantity Limits
• Monitoring Data
Date of Sample
Concentration or Quantity of Each Parameter
Average Concentration or Quantity of Each Parameter
Type of Monitoring Sample (Self-Monitored, Scheduled,
Unscheduled, Demand)
-------
A-10
Alternative 4 Contents, Continued:
• Industrial User Technological Compliance Schedule
* Industrial User Inspections by Control Authority
Date of Inspection
Type of Inspection
• Slug Load Data
• Enforcement Actions Taken (Detailed Data)
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A- 11
Oata to be Contained In Alternative 5
Source: POTW Pretreatment Performance Summary
Alternative 5 will contain the same data from the Pretreatment
Performance Summaries as Alternative 2 including:
0 Geographic Information About POTWs and Counts of lUs
— NPDES Number
Name, Address, Contact Person, Telephone Number, etc.
(Some of this data may be referenced from other PCS files and
not duplicated here.)
Total Number of Categorical lUs
Total Number of Noncategorical lUs
Reporting Period
• Significant Industrial User Compliance Data (Summary level data
would include separate listings for categorical and noncategorical
users, except where noted)
No. of SIUs Submitting BMRs/No. Required (Categorical Only)
No. of SIUs Submitting 90-Day Compliance Reports/No. Required
(Categorical Only)
No. of SIUs Submitting Semi-Annual Report/No. Required
No. of SIUs Meeting Compliance Schedule/No. Required to Meet
Schedule
No. of SIUs in Significant Noncompliance/Total No. of SIUs
Rate of Significant Noncompliance for all SIUs (Categorical
and Noncategorical Combined)
• Compliance Monitoring Program Data (Summary level data would
include separate listings for categorical and noncategorical
users)
-- No. of Non-Sampling Inspections Conducted
No. of Sampling Visits Conducted
No. of Facilities Inspected (Non-Sampling)
No. of, Facilities Sampled
• Enforcement Actions Data (Summary level data would include
separate listings for categorical and noncategorical users)
Compliance Schedules Issued/Schedules Required
Notices of Violations Issued to SIUs
Administrative Orders Issued to SIUs
— Civil Suits Filed
Criminal Suits Filed
— Significant Violators
Was Significant Violators List Published
Amount of Penalties Collected (Total Dollars/IU Assessed)
Other Actions (Sewer Bans, etc.)
-------
A-13
Alternative 5 Contents, Continued:
Source: Pretreatment Compliance Inspections and Program Audits
Alternative 5 will contain the same data from Pretreatment Compliance
Inspections and Program Audits as Alternative 3, including summary data
concerning:
t PCI / Audit Identification Data
— POTW NPOES Code
Date of PCI or Audit
Name of Auditor(s) or Inspectors(s)
Control Authority Representative
• Control Authority Pretreatment Program Overview Data
Number of Categorical Industrial Users
Number of Significant Noncategorical Industrial Users
Number of Noncategorical Industrial Users
Local Definition of "Significant Industrial User"
Percentage of Total Wastewater Flow to POTW that is
Attributed to Industrial Users
Recent Changes to Control Authority Pretreatment Program
• Control Authority Inspection and Monitoring of Industrial Users
Indicators About the Frequency of Inspections of Categorical
and Significant Noncategorical lUs
Indicators About the Frequency of Control Authority Sampling
of Categorical and Significant Noncategorical lUs
Percentage of SIUs Not Inspected in the Past Year
Percentage of SIUs Not Sampled in the Past Year
Data About the Frequency of Sampling and Self-Monitoring
Reports Conducted by Categorical and Significant
Noncategorical lUs
• Count of SIUs Covered by a Control Mechanism
Number- and Percentage of SIUs Covered by an Existing,
Unexpired Permit, Contract, or Other Control Mechanism.
Number and Percentage of Permits That Need to be Issued
• IU Compliance and Enforcement Actions Data (Summary level only)
Percentage of All lUs Which Needed to Install Pretreatment
Technologies and Have Done So.'
Percentage of SIUs in Significant Noncompliance with
Applicable Pretreatment Standards
Percentage of SIUs in Significant Noncompliance with
Self-Monitoring Requirements
Percentage of SIUs in Significant Noncompliance with
Reporting Requirements
Percentage of SIUs Subject to Some Kind of Enforcement Action
During Past Year
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A-13
Alternative 5 Contents, Continued:
IU File Evaluation Data
Ranking or Code to Indicate the Adequacy
Deficiencies in the POTW IU Files Examined
and Any Major
• Evaluation Comments of Inspector/Auditor (To Be Stored as a Set of
Ranking Codes)
Codes Ranking the POTW's Monitoring Program
Codes Ranking the POTW's Control Mechanisms
Codes Ranking IU Self-Monitoring Data and Reports
Codes Ranking Control Authority Enforcement Procedures
Codes Describing Other Findings
Codes Describing Suggested Follow Up Actions -
• Background Control Authority Data
There was a substantial amount of other data in the Program
Audit checklist that may be very useful for background data,
since it may not change significantly over time. EPA will
have to decide what data should be kept on-line for
background purposes.
Source: Various Industrial User Reports
In Alternative 5, participating Approval Authorities will decide which
Industrial Users and how much data they will track.
t General Industrial User Identification Data
Permit or Contract Number
Name of Industrial User
Contact Person
Telephone Number
— SIC Codes
• Sampling and Reporting Requirements
Required Sampling Frequency
Actual Sampling Frequency
Required Date of Report Submission
Actual Date of Report Submission
• _Pollutant Limits Data
. — Pollutant Parameters
Maximum Concentration and Quantity Limits
Minimum Concentration and Quantity Limits
Average Concentration and Quantity Limits
Minimum Average Concentration and Quantity Limits
Production Based Limits
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A-14
Alternative 5 Contents Continued:
• Monitoring Data
Date of Sample
Concentration or Quantity of Each Parameter
Average Concentration or Quantity of Each Parameter
Type of Monitoring Sample (Self-Monitored, Scheduled,
Unscheduled, Demand)
Production Level
• Industrial User Technological Compliance Schedule
• Industrial User Inspections by Control Authority
Date of Inspection
Detailed Results of Inspection
Suggested Follow Up Actions
• Slug Load Data (Detailed Data)
t Enforcement Actions Taken (Detailed Data)
-------
PART IV: PRETREATMENT PERMITS AND ENFORCEMENT TRACKING SYSTEM
INITIAL SYSTEM DESIGN
-------
TABLE OF CONTENTS
Page
I. PPETS INITIAL SYSTEM DESIGN INTRODUCTION .1-1
II. STEP 1: SYSTEM FOR APPROVAL AUTHORITIES AND HIGHER LEVELS . II-l
A. Step 1 Overall System Description II-l
B. Step 1 Input Data II-4
C. Step. 1 Output Reports 11-6
D. Step 1 File Structure 11-22
E. Step 1 Software Functions 11-25
F. Step 1 Data Element Listing 11-27
III. STEP 2: SYSTEM FOR APPROVAL AUTHORITIES AND HIGHER LEVELS
(WITH LIMITED INDUSTRIAL USER DATA) III-l
A. Step 2 Overall System Description I II-l
B. Step 2 Input Data 111-4
C. Step 2 Output Reports II1-6
D. Step 2 File Structure 111-14
E. Step 2 Software Functions . 111-17
F. Step 2 Data Element Listing . 111-19
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1-1
I. PPETS INITIAL SYSTEM DESIGN INTRODUCTION
The National Pretreatment Program requires that EPA implement nationwide
regulations controlling the pollutants discharged to Publicly Owned Treatment
Works (POTWs) by Industrial Users (lUs). EPA.initiated a study to determine
the information requirements necessary to oversee the program implementation
and regulation; the results were presented in the Summary of Pretreatment
Tracking Needs.
From this study, a general definition and design were developed for a
Pretreatment Permits and Enforcement Tracking System (PPETS). PPETS will be
an information system, designed to help EPA and delegated States implement and
enforce pretreatment regulations. The system will provide EPA Headquarters
with summary pretreatment statistics to highlight problem areas and help EPA
direct its resources toward the greatest needs. PPETS will also provide more
detailed pretreatment data for EPA Regions and delegated State Approval
Authorities to help them with local oversight and enforcement of pretreatment
programs.
. The PPETS system will be implemented in a two step approach:
• Step 1: Implementation of an automated system to track data
from Pretreatment Compliance Inspections (PCIs),
Pretreatment Program Audits, and Pretreatment
Performance Summaries.
• Step 2: Enhancement of the PPETS system to track certain data
for a limited number of Industrial Users.
The Step 1 PPETS system corresponds to the proposed Alternative 3 system
defined in the Evaluation of Alternatives for the Pretreatment Permits and
Enforcement Tracking System. The Step 2 system corresponds to Alternative 4.
The phased approach is recommended for two reasons. First, it will
expedite the creation of an automated pretreatment tracking system to meet
EPA's immediate needs. Second, it will provide time for EPA Regions and
delegated States to develop and implement their pretreatment programs, before
-------
1-2
the full PPETS system becomes operational. Exhibit 1-1 contains a timeline
illustrating the development of PPETS in relationship to Pretreatment Program
activities.
Both Steps 1 and 2 will be implemented as enhancements to the current
Permits Compliance System (PCS). This will reduce the need for purchases of
new computer equipment, and should facilitate PPETS training since personnel
in EPA Regions and some delegated States are already familiar with PCS.
Because the tracking requirements that would be met by PPETS are very similar
to those of PCS, many PCS software modules could be modified to support PPETS,
thus reducing the development cost of the system. In addition, it will help
ensure the consistency and compatibility of data in EPA tracking systems.
This document provides an initial design for the PPETS system. It
presents a basic logical system design and describes the capabilities required
by PPETS users. The document should form the basis of a detailed PPETS design
and workplan to be developed by EPA.
The paper is divided into two main sections -- one focusing on Step 1 and
the other on Step 2. Each section contains six parts:
• Overall System Description
• Input Data
• Output Reports
• File Structure
• Software Functions
• Data Element Listing.
-------
1-3
ID PRETREATMENT PROGRAM TIMELINE
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-------
II-l
II. STEP 1: SYSTEM FOR APPROVAL AUTHORITIES AND HIGHER LEVELS
A. Step 1 Overall System Description
In Step 1, EPA will develop a version of the Pretreatment Permits and
Enforcement Tracking System (PPETS) that should serve many of the needs of EPA
Headquarters, EPA Regional Offices, and delegated State Approval Authorities.
In particular, Step 1 should support pretreatment decision making in the
following areas:
• Determine the Effectiveness of the National Pretreatment
Program (NPP)
• Evaluate Regional Oversight Effectiveness
* Determine POTW Compliance with Pretreatment Program
Implementation Requirements
• Determine Significant Industrial User Pretreatment Compliance
• Evaluate State and Local Program Effectiveness.
In order to support these data needs, the system will rely on several key
input documents, including Pretreatment Compliance Inspections (PCIs),
Pretreatment Program Audits, and Pretreatment Performance Summaries (PPSs).
EPA has issued pretreatment guidances containing suggested formats for PCI
checklists, Program Audit checklists, and PPSs. These suggested formats will
form the basis of the Step 1 PPETS system.
Step 1 will be designed and implemented as an enhancement to the current
Permit Compliance System. Two new files, the PCI-Audit and PPS-Data files,
will be added to PCS. PCS was chosen as the basis for PPETS for several
reasons. First, much of the pretreatment data will have greater utility when
combined with current NPDES data. For example, it may be useful to examine
whether POTWs with NPDES violations also have poor records of pretreatment
enforcement and compliance. Second, designing the system as a modification to
PCS will ensure the consistency and compatibility of all data. In addition,
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II-2
personnel at EPA and many delegated States already have a basic understanding
of PCS, and a PCS implementation will probably cost less than developing a
whole new system.
As an expansion of the PCS system, PPETS will be implemented on the EPA
IBM 3090 Mainframe in Research Triangle Park, North Carolina. PCS is
connected to the EPA Regions and States via terminals and telecommunication
lines. A diagram illustrating the major data flows for Step 1 is contained in
Exhibit II-l.
PPETS will provide EPA Headquarters, Regions, and delegated States with
new standard reports summarizing pretreatment data nationwide, region-wide,
statewide, and even by POTW. In addition, users will be able to request Quick
Look Reports to list data in user-designed formats. The system will provide
consistent national pretreatment statistics and identify problem areas in
national and local pretreatment programs. PPETS will help point out areas of
pretreatment program implementation and enforcement that require special
attention by EPA and the delegated States.
PPETS will be designed to be user-friendly.. The data will be readily
accessible to all program staff at EPA Headquarters, Regions, and Approval
Authorities. Personnel who are untrained in computer programming should have
no trouble accessing the data. New software routines will be required to
enter, update, and manipulate the PPETS data. This additional software will
be compatible with. PCS, so that personnel currently using PCS should have no
trouble learning PPETS.
Although the Step 1 PPETS system will be developed as a single package,
its usage will be phased in over time. This will allow sufficient time for
the EPA Regions and delegated States to implement the necessary programmatic
procedures to support the automated system. In particular, the Pretreatment
Program Audit - and Pretreatment Compliance Inspection tracking capabilities
will be used first. Pretreatment Performance Summary capabilities will be
phased in later, as PPS procedures are standardized and Control Authorities
become better able to submit more timely and accurate pretreatment statistics.
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II-4
Step 1 Input Data
The Step 1 PPETS system will rely on three major input documents as
sources of pretreatment data. The inputs are:
• Pretreatment Compliance Inspections (PCIs)
• Pretreatment Program Audits
• Pretreatment Performance Summaries (PPSs).
Pretreatment Program Audits and PCIs are currently being performed on Control
Authorities by EPA Regions or delegated State Approval Authorities. PPSs have
been proposed to be included with Control Authority Annual Reports.
Pretreatment Compliance Inspections are intended to be performed annually
(except in Program Audit years) for each Control Authority. The purpose of
the PCI is to evaluate an approved POTW pretreatment program. The PCI is
designed to verify the compliance status of the POTW and focuses primarily on
the compliance monitoring and enforcement activities of the POTW.
Program Audits are also performed as a means of evaluating pretreatment
program implementation. However, the audit is a comprehensive review of all
elements of an approved POTW pretreatment program. Each Control Authority is
scheduled to be audited at least once every five years.
Pretreatment Performance Summaries are one page statistical summaries
describing a Control Authority's pretreatment program enforcement. They
contain information on general POTW characteristics, Significant Industrial
User compliance, the compliance monitoring program, and enforcement actions
taken.
EPA has issued suggested checklists for PCIs and Program Audits, and a
suggested format for PPSs. These suggested formats will be the basis of the
Step 1 PPETS system. However, implementation of PPETS may require several
changes to these input formats and reporting procedures. More rigorous data
and submission procedures will be necessary to support a consistent and
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II-5
reliable tracking system. Some of the changes that may be needed include:
• Suggested formats for PCI checklists, Program Audit checklists,
and PPSs may have to be made mandatory.
• Standardized schedules will have to be developed for data
submission.
t Data from delegated State Approval Authorities that decide not
to participate in PPETS will have to be passed to the
responsible EPA Regions.
• Standard definitions for data elements and classifications used
on PPSs, PCIs, and Program Audit checklists—such as
'Significant Industrial User1 and 'Significant Noncompliance1--
should be developed.
These changes may take some time to be developed. They must be
implemented, however, if PPETS is to meet EPA's requirements. Although it may
be feasible to phase in some of these changes during the first 6 to 18 months
of PPETS operations, they are critical to PPETS1s success.
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11-6
C. Step 1 Output Reports
Output reports will be very important in determining the usefulness of
PPETS in meeting EPA's needs. Below are listed twenty-six suggested reports.
Two are modifications of current PCS reports:
• Quick Look Report
• Milestone Report.
Fourteen would be new standardized reports designed for PPETS and derived
from the PCI and Program Audit data:
• Pretreatment Compliance Inspection (PCI) Report
• Pretreatment Program Audit Report
• Control Authority Pretreatment Program Overview Report
* Control Authority Pretreatment Program Trend Overview
• Control Authority Pretreatment Program Modification Update
Report
t IU Inspection and Monitoring Deficiency Report
• Control Mechanism Deficiency Report
t Enforcement Procedure Cross-sectional Comparison Report
t Compliance Tracking Deficiency Report
• File Evaluation Deficiency Report
t Control Authority Pretreatment Program Deficiency
Cross-sectional Summary
• Control Authority Pretreatment Program Deficiency Trend Summary
• PCI and Program Audit Data Status Report
• Control Authority Mailing Labels.
Ten additional new standardized reports will be derived from PPS data:
• Control Authority Pretreatment Performance Summary
• PPS Aggregate Totals Summary Report
• SIU Compliance Cross-sectional Comparison Report
• Compliance Monitoring Program Cross-sectional Comparison Report
-------
II-7
• Enforcement Actions Cross-sectional Comparison Report
t Sill Compliance Trend Report
§ Compliance Monitoring Program Trend Report
• Enforcement Actions Trend Report
• PPS Verification Report
• Regulated Industrial User Summary Location Report.
The above listings are only suggested output reports. Other reports and
applications of PPETS data can be developed when needs arise.
Currently, different Approval and Control Authorities have different
submission schedules for PCIs, Program Audits, and PPSs. Most PPETS data will
probably be updated, continuously throughout the year. Outputs based on this
data, therefore, will not reflect conditions on a specific date with full
accuracy, but will be compiled from the latest information available.
The following sections describe each of the suggested reports in greater
detail. For selected reports, sample formats have been provided to give a
more concrete idea of how PPETS outputs could be used; these formats are
preliminary samples only and will require extensive review by program
personnel before being finalized.
Modified PCS Reports
1. Quick Look Report
PPETS users will have access to the PCS Quick Look Report. The Quick Look
Report is a flexible report that gives the user control over the contents and
design of the output in order to meet specialized information needs. The
Quick Look Report software will have to be modified for PPETS, but will still
have procedures and formats similar to those currently in.PCS. An example of
a Quick Look Report that could be used in PPETS would be any subset of PCI
data listed out by the POTW's NPDES Number.
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II-8
2. Milestone Report
PPETS users will also have access to the current PCS Milestone Report.
The Milestone Report provides the user with a tally in matrix format of the
number of occurrences of different data values for any two data elements. The
Milestone Report software will have to be modified for PPETS, but will still
have procedures and formats similar to those currently in PCS. An example of
a Milestone Report that could be used in PPETS would be the number of Control
Authorities, within different States, which have published lists of
significant violators, and the total number of Control Authorities within each
State.
PPETS Standard Reports Derived From PCI and Program Audit Data
3. Pretreatment Compliance Inspection (PCI) Report
The Pretreatment Compliance Inspection Report lists all the data stored in
PPETS from a specific PCI. Users will specify a particular PCI by identifying
the Control Authority and inspection year. (Specifying a month may also be
necessary.) This report will give detailed information about a specific
Control Authority, and will probably be especially useful to the supervising
Approval Authority. .
4. Pretreatment Program Audit Report
The Pretreatment . Program Audit Report lists all the data stored in PPETS
from a specific Program Audit. Users will specify a particular Program Audit
by identifying- the Control Authority and audit year. This" report will give
detailed information about a specific Control Authority, and will probably be
especially useful to the supervising Approval Authority.
-------
II-9
5. Control Authority Pretreatment Program Overview Report
The Control Authority Pretreatment Program Overview Report provides
overview data from PCIs for the Control Authorities across a State or Region.
Some data to be included may be the number of Industrial Users, percentage of
III wastewater flow, and sludge contamination from lUs.
6. Control Authority Pretreatment Program Trend Overview
The Control Authority Pretreatment Program Trend Overview Report will
track PCI overview data for a particular Control Authority over a period of
time (perhaps 5 years). Some of the data may include the number of Industrial
Users, percentage of IU wastewater flow, and incidences of sludge
contamination due to IU wastes. The report will illustrate how the general IU
characteristics in a Control Authority's jurisdiction have changed over time.
7. Control Authority Pretreatment Program Modification Update Report
The Control Authority Pretreatment Program Modification Update Report will
list all the Control Authorities, within a particular jurisdiction (State,
Sub-Region, Region), that have made modifications to their pretreatment
programs. The report will include the data identifying the Control Authority
(name, NPDES number, etc.), the program elements changed, and whether the
change was submitted for approval. This report will be especially useful to
Approval Authorities to ensure that their files accurately reflect the
programs in place at the Control Authorities. Exhibit II-2 contains a sample
format for this report.
8. IU Inspection and Monitoring Deficiency Report
The IU Inspection and Monitoring Deficiency Report will list those Control
Authorities where PCIs have uncovered deficiencies in procedures for the
inspection and monitoring of Industrial Users. For a given State, Approval
-------
11-10
CONTROL AUTHORITY PRETREATMENT PROGRAM
MODIFICATION UPDATE REPORT
Approval Authority: AAAAAAA
Date From: MM/DD/YY
To: MM/OD/YY
Control Authority
Identification
Program Element Changed
POTW: BBB8BBBBBBB Legal Authority
NPDES # 111111111 Resources
Submitted for
Approval
Yes
No
POTW: CCCCCCCCCCC
NPOES # 222222222
Control Mechanism Implementation
Yes
POTW: DDDDDODDDDD
NPDES I 333333333
Local Limits
Inspection and Monitoring Program
Yes
Yes
POTW: EEEEEEEEEEE Enforcement Program
NPDES I 444444444
No
EXHIBIT II-2
-------
11-11
Authority, Region, or the Nation, this report will list all the deficient
Control Authorities and the types of problems found. The report will help
point out those areas where the delegated States and EPA Regions should direct
their efforts. Exhibit II-3 contains a sample format for this report.
9. Control Mechanism Deficiency Report
The Control Mechanism Deficiency Report will list those Control
Authorities where PCIs have uncovered deficiencies in existing control
mechanisms. For a given State, Approval Authority, Region, or the Nation,
this report will list all the deficient Control Authorities, the types of
problems found, and the percentage of SIUs not currently covered by a control
mechanism. The report will help point out areas where the delegated States
and EPA Regions should direct their efforts. The format for the report will
be similar to the format for the ID Inspection and Monitoring Deficiency
Report illustrated in Exhibit II-3.
10. Enforcement Procedure Cross-sectional Comparison Report
The Enforcement Procedure Cross-sectional Comparison Report will compare
enforcement procedure data from PCI checklists across different jurisdictions
and oversight areas. Data about noncompliance rates, types of enforcement
actions taken, and enforcement procedures could be compared among Control
Authorities, Approval Authorities, States, and Regions. Users will be able to
specify the level of detail they require.
11. Compliance Tracking Deficiency Report
The Compliance Tracking Deficiency Report will list those Control
Authorities where PCIs have uncovered deficiencies in compliance tracking.
For a given State, Approval Authority, Region, or the Nation, this report will
list all the deficient Control Authorities and the types of problems found.
The report will help point out those areas where the delegated States and EPA
-------
11-12
IU INSPECTION AND MONITORING DEFICIENCY REPORT
Approval Authority: AAAAAAA;
Date from: MM/DD/YY
to: MM/OD/YY
Control Authority
POTW: BBBBBBB8B6B
NPDES I 111111111
Deficiency Found
2Q% of SIUs not sampled during past year.
30% of SIUs not inspected during-past year.
POTW: CCCCCCCCCCC
NPDES # 222222222
10% of SIUs not inspected during past year.
POTW: DDDDDODDDDD
NPDES # 333333333
Categorical lUs are not required to perform and
submit self-monitoring reports at least twice a
year.
POTW: EEEEEEEEEEE
NPDES I 444444444
15% of SIUs not sampled during past year.
2555 of SIUs not inspected during past year.
EXHIBIT II-3
-------
; 11-13
Regions should direct their efforts. The format for the report will be
similar to the format for the III Inspection and Monitoring Deficiency Report
illustrated in Exhibit II-3.
12. File Evaluation Deficiency Report
The File Evaluation Deficiency Report will list those Control Authorities
where PCIs have uncovered deficiencies in Industrial User files. For a given
State, Approval Authority, Region, or the Nation, this report will .list all
the deficient Control Authorities and the types of problems found. The report
will help point out those areas where the delegated States and EPA Regions
should direct their efforts. The format for the report will be similar to the
format for the 1U Inspection and Monitoring Deficiency Report illustrated in
Exhibit II-3.
13. Control Authority Pretreatment Program Deficiency Cross-sectional
Summary
The Control Authority Pretreatraent Program Deficiency Cross-sectional
Summary will be a statistical summary of PCI results. For a given State,
Region, or the Nation, the report will list the number of Control Authorities
which had deficiencies in each pretreatment program area. The report will
help point out those areas which Control Authorities are having the most
trouble implementing, so that EPA and the States can target their efforts
accordingly. Exhibit II-4 contains a sample format for this report. It would
list National and Regional statistics for Control Authorities with
pretreatment program deficiencies.
14. Control Authority Pretreatment Program Deficiency Trend Summary
The Control Authority Pretreatment Program Deficiency Trend Summary will
be a statistical summary of PCI results over a period of time (perhaps 5
years). Users will specify the focus of the report, whether it is for a
-------
11-14
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Control Authority, Approval Authority, State, Region, or the Nation. The
report will list the number of Control.Authorities, within the jurisdiction,
which had deficiencies in each pretreatment program area for each of the last
few years. The report will help point out those areas of pretreatment where
improvement has occurred and those areas that need additional attention.
15. PCI and Program Audit Data Status Report
The PCI and Program Audit Data Status Report will describe-the current
status of the PCI and Program Audit data in the PPETS system. It will include
the number of Control Authorities for which data is available, the number for
which data is unavailable, and dates indicating the timeliness of the data.
The report could list summary statistics for States, Regions, or the Nation,
or it could list the specific Control Authorities by NPDES number and name.
16. Control Authority Mailing Labels
This report will print out mailing labels for all the Control Authorities
within an Approval Authority's, State's, or Region's jurisdiction. The
mailing labels could be printed with or without the cognizant official's name.
PPETS Standard Reports Derived From PPS Data
17. Control Authority Pretreatment Performance Summary
The "Control Authority Pretreatment Performance Summary Report will print
out a full Pretreatment Performance Summary for a specific Control Authority
or POTW for a specific year. The report will be similar to the format
contained in the EPA Pretreatment Compliance Monitoring and Enforcement
Guidance. This report will give relatively detailed pretreatment statistics,
including Significant Industrial User compliance data, Compliance Monitoring
.Program data, and Enforcement Action data. It should be especially useful to
Approval Authorities overse'eing POTWs.
-------
11-16
18. PPS Aggregate Totals Summary Report
The PPS Aggregate Totals Summary Report aggregates the statistics on the
PPS reports for an entire Approval Authority, State, Region, or for the
Nation. The format will be the same as for the standard PPS report defined by
EPA guidance, but the broader statistics will be more useful for EPA Regions
and Headquarters.
19. SIU Compliance Cross-sectional Comparison Report
The SIU Compliance Cross-sectional Comparison Report will compare the SIU
Compliance data from PPS reports across different jurisdictions and oversight
areas. The report will include data about the reporting, discharge, and
schedule compliance of Categorical and Noncategorical lUs. The report will
give users the option to specify the level of detail they require, whether it
is statistics for Control Authorities, or aggregate statistics for Approval
Authorities, States, or Regions. Approval Authorities will be able to compare
compliance rates across the Control Authorities they oversee and will be able
to allocate their resources to the greatest need. EPA Headquarters and
Regions could compare compliance among Approval Authorities and States and
also focus their resources accordingly. Exhibit II-5 contains a sample format
for this report. The format provides statistics for different Control
Authorities and provides totals for the supervising Approval Authority.
20. Compliance Monitoring Program Cross-sectional Comparison Report
The Compliance Monitoring Program Cross-sectional Comparison Report will
compare Compliance Monitoring Program data from PPS reports across different
jurisdictions and"oversight areas. The data will include the number and types
of pretreatment visits and inspections conducted by Control Authorities.
Users will be able to specify the level of detail they require, whether it is
statistics for Control Authorities, or aggregate statistics for Approval
Authorities, States, or Regions. Approval Authorities will be able to compare
Monitoring Program data for the Control Authorities they oversee. EPA Regions
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Headquarters will be provided with a full set of oversight data for Control
Authorities, Approval Authorities, States, and Regions. The format for the
report will be similar to the format for the SIU Compliance Cross-sectional
Comparison Report illustrated in Exhibit II-5.
21. Enforcement Actions Cross-sectional Comparison Report
The Enforcement Actions Cross-sectional Comparison Report will compare
enforcement actions data from PPS reports across different jurisdictions and
oversight areas. The data will include the number and types of enforcement
actions taken by Control Authorities against pretreatment violators. Users
will be able to specify the level of detail they require, whether it is
statistics for Control Authorities, or aggregate statistics for Approval
Authorities, States, or Regions. Approval Authorities will be able to compare
enforcement data for the Control Authorities they oversee. EPA Regions will
be able to compare data across Approval Authorities and States. The EPA
Headquarters will be provided with a full set of oversight data for Control
Authorities, Approval Authorities, States, and Regions. The format for the
report will be similar to the format for the SIU Compliance Cross-sectional
Comparison Report illustrated in Exhibit II-5.
22. SIU Compliance Trend Report
The SIU Compliance Trend Report will track the PPS SIU Compliance data for
a particular jurisdiction over a period of time (perhaps 5 years). Users will
choose a specific Control Authority, Approval Authority, State, or Region to
be reported. National statistics and trends will also be available. The
report will -contain data describing the reporting, discharge, and schedule
compliance rates for the chosen jurisdiction over a period of years. The
report will help identify trends in pretreatment compliance; it will point out
those areas of compliance that are improving and those that need special
attention. Exhibit II-6 contains a sample format for this report. It would
list the SIU Compliance Trend data for a specific Control Authority over 5
years and provide average compliance statistics during that period.
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11-20
23. Compliance Monitoring Program Trend Report
The Compliance Monitoring Program Trend Report will track the PPS
Compliance Monitoring Program data for a particular jurisdiction over a period
of time (perhaps 5 years). Users will choose a specific Control Authority,
Approval Authority, State, or Region to be reported. National statistics and
trends will also be available. The report will contain data describing the
number and types of pretreatment visits and inspections conducted in the
chosen jurisdiction over a period of years. The report will help identify
trends in pretreatment compliance monitoring; it will point out which areas
are improving and which need special attention. The format for the report
will be similar to the SIU Compliance Trend Report illustrated in
Exhibit 11-6.
24. Enforcement Actions Trend Report
The Enforcement Actions Trend Report will track the PPS Enforcement
Actions data for a particular jurisdiction over a period of time (perhaps 5
years). Users will choose a specific Control Authority, Approval Authority,
State, or Region to be reported. National statistics and trends will also be
available. The report will contain data describing the number and types of
enforcement actions taken by Control Authorities against, pretreatment
""violators within the chosen jurisdiction over a period of years. The report
will help identify trends in pretreatment enforcement; it will point out which
areas are improving and which need special attention. The format for the
report will be similar to the SIU Compliance Trend Report illustrated in
Exhibit II-6.
25. PPS Verification Report
The PPS Verification Report will help verify that the data submitted by
Control Authorities on Pretreatment Performance Summaries is consistent with
data on PCIs and Program Audits. The report will list out those Control
Authorities where significant discrepancies have been found. Since it is
-------
11-21
likely that much of data will not match precisely, criteria will have to be
established as to what is a significant discrepancy. This criteria may take
the form of a fixed percentage, and a Control Authority will be listed on the
report, if the variation between analogous data elements is greater than that
percentage. This fixed percentage criteria may be incorporated into the
software or entered by the user when the report is requested.
26. Regulated Industrial User Summary Location Report
The Regulated Industrial User Summary Location Report will list the total
number of regulated Categorical lUs and Significant Noncategorical lUs within
the jurisdiction of a Control Authority, Approval Authority, State, Region, or
the Nation. The number of lUs will be calculated from the latest information
available or for any past date entered by the user.
-------
11-22
Step 1 file Structure
Step 1 will be implemented as two new data files in PCS, as illustrated in
Exhibit II-7. The proposed new files are:
• PCI-Audit Data File
• PPS-Oata File.
The PCI-Audit file will be logically linked to the current PCS Inspection
file. The PCI-Audit records will correspond to records in the Inspection file
and will be uniquely identified by NPDES Number and Inspection Date. PCI data
will be stored in approximately 40 data fields, and Program Audit data will be
stored in approximately 61 fields. Much of the background data about the name
and location of the Control Authority facility will be referenced from the
current PCS Permit-Facility data file in order to reduce any overlap of data.
Each Program Audit stored will use approximately 230 to 383 bytes of
storage. PCIs will use approximately 69 to 115 bytes of storage. Program
Audits are expected to be performed once every five years for POTWs with
approved pretreatment programs; PCIs are expected to be performed annually in
non-audit years. It is therefore expected that data from approximately 292
Program Audits and 1,169 PCIs will be added to the file each year, or that
from 148 to 246 kilobytes of storage will be used each year.
The PPS-Data file will be a separate module in PCS, logically linked to
the Permit-Facility file. Each record in the PPS-Data file will contain
approximately 46 data elements and be uniquely identified by its NPDES number
and PPS Reporting Period Start and End Dates. Background data about the name
and location of the Control Authority facility will be referenced from the
Permit-Facility data file, so there should be little or no overlap of data.
Each PPS-Data record will contain approximately 190 to 318 bytes of
information. After all of the local pretreatment programs are approved
nationwide, it is estimated that PPETS will have to store data for 1,510
POTWs. This means that from 287 to 480 kilobytes of data will be added to the
-------
11-23
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11-24
system during each PPS reporting period. The overall size of the PPS-Data
file will depend upon the number of year's data kept on-line and whether PPS
updates will be required once a year or more often.
One issue that will have to be resolved is how to classify those PPSs that
are compiled by Approval Authorities. There are two suggested methods for
doing this, depending upon whether the Approval Authority is responsible for
completing one PPS for all of the POTWs for which it acts as Control
Authority, or one PPS for each of these POTWs. If the Approval Authority has
to complete only one PPS each year, then the data could be entered into PPETS
with a dummy NPDES number referring to the Approval Authority. If the
Approval Authority completes a PPS for each POTW where it acts as Control
Authority, then those PPSs could be entered under the POTWs NPDES number
along with an additional code indicating that the PPS was completed by the
Approval Authority.
-------
11-25
E, Step I Software Functions
Implementation of Step 1 will require adding new software routines to PCS
for entry and manipulation of PPETS data. Several PCS programs will have to
be modified including:
• "PCS Edit Program
• PCS-ADE Program
• PCS Update Program
• PCS Retrieval Reports
• PCS Sequential File Extract
• PCS Archival Procedures.
The PCS Edit program is a batch program used to enter, modify, and delete
data in the PCS system. Users create a separate file of new records and data
modifications to be added to PCS. The Edit program checks the entries for
accuracy and stores them in a temporary file to await a PCS update. The
program .creates a report, that is sent to the user, describing the results of
the batch run and indicating any errors found. Twice a week, the PCS Update
program is run to load data from the temporary files into the actual PCS
files. The PCS-ADE program performs functions similar to the Edit program
except that it is interactive.
Step 1 will require new software modules be added to the PCS Edit and
PCS-ADE programs, along with some modifications to the current modules. Any
new software modules should be designed for simplicity of use and must
maintain PCS security measures. The modules also must perform edit checks to
help ensure reliable data. For example, edit checks may ensure that PCI,
Audit, and PPS data can only be entered for POTWs which have an established
facility record. In addition, the PCS Update program will require
modifications, .so that it can handle the new PPETS data.
Two current PCS retrieval reports, the Quick Look and Milestone reports,
will be very useful for analyzing PPETS data. The software for these reports
will have to be modified to accept data from the new PCI-Audit and PPS-Data
-------
11-26
files. Additional retrieval software will be required to implement the Step 1
standard reports previously described.
The Sequential File Extract creates tape data sets of PCS information.
The data on these tapes can then be downloaded onto Regional and State systems
or manipulated using high-level languages, like SAS and FOCUS. Step 1 will
require modification of the Sequential File Extract software to include the
PPETS data.
PCS archival procedures may also require modification for PPETS. Under
current procedures, a data archival takes place once a year. During the
archival, measurement data that is more than 2 years old is moved to a
separate area of the data base. The information is still kept on-line, but it
is in a less frequently used area of memory; this expedites retrievals of more
current data. It is expected that at some time in the future, the oldest data
in PCS will have to be archived to tapes or disks. At least 5 years of Step 1
PPETS data should be kept on-line. This will facilite use of the PPETS trend
reports described earlier.
All of the above software modifications will have to include transaction
auditability data to record system usage. In the event of problems, this data
could trace system usage to help resolve difficulties. As with the current
PCS system, the PPETS transactions data will have to be obtained from the PCS
User Support Staff.
-------
11-27
F- Step 1 Data Element Listing
The Step 1 data elements will be derived from report formats contained in
current EPA guidances. These report formats include:
• Pretreatment Compliance Inspection (PCI) Checklists
• Pretreatment Program Audit Checklists
• Pretreatment Performance Summaries (PPS).
The PCI and Program Audit Checklists include data from a wide variety of
Pretreatment areas Including: program overview, program modifications,
inspection and monitoring procedures, control mechanism evaluation,
enforcement procedures, compliance tracking procedures, and IU file
evaluation. Much of the data from the checklists will be useful to the PPETS
system. It is currently estimated that PPETS will track 48 data element
fields from PCIs and 69 fields from Program Audits. The two checklists have
some elements in common and some elements that overlap with current PCS data.
When a detailed record structure is developed for the PCI-Audit file, it
should be designed to maximize the number of common data definitions between
the two checklists, while minimizing any data duplication with other PCS
files.
The current PPS format contained in the EPA Pretreatment Compliance
Monitoring and Enforcement Guidance will require up to 54 data element fields
to store all of the listed information. (The exact number of data elements
may vary depending upon the implementation design chosen.) Some of the
background data from the general information section of the PPS is currently
stored in the Permit-Facility data file in PCS. This data will be referenced
from there and not duplicated in the PPS-Data file. All the rest of the PPS
data elements can be combined to form a single record structure with the NPDES
number and PPS Reporting Period Dates serving as identifying indices. These
additional records would be stored in the PPS-Data file to be added to PCS.
-------
11-28
Exhibits 11-8, II-9, and 11-10 contain detailed lists of the elements
required to track the data contained on PCIs, Program Audits, and PPSs. The
data element names are descriptive and were written to facilitate review of
the list by management. The actual data element names will probably change
when the system is implemented, but the data represented should remain the
same.
In addition to the data actually on PCIs, Audits, and PPSs, the system
will need to determine the levels of pretreatment oversight. Each POTW must
have data indicating whether it Is a Control Authority, whether the State or
Region is acting as Control Authority, and whether the State or Region is
acting as Approval Authority. This information is important when organizing
the data into logical outputs. The implementation of this requirement is a
detailed design issue that will have to be decided in the final PPETS system
design.
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-------
III-l
HI. STEP 2: SYSTEM FOR APPROVAL AUTHORITIES AND HIGHER LEVELS
(WITH LIMITED INDUSTRIAL USER DATA)
A. Step 2 Overall System Description
After Step 1 is fully operational, EPA will develop the Step 2
Pretreatment Permits and Enforcement Tracking System (PPETS). During this
step, EPA will significantly enhance the PPETS system to track certain
Industrial User pretreatment data for a limited number of lUs. The
enhancement should serve as a valuable aid to EPA Regions and delegated State
Approval Authorities for enforcing pretreatment regulations. For those
Industrial Users tracked, the system will store data on:
• Industrial User Facilities
• .Compliance Schedules
• Compliance Schedule Violations
0 Discharge Limits
• Sampling Measurements
• Discharge Violations
• Enforcement Actions
• Permitting Events
• ID Inspections.
In order to support these data, the system will rely on a wide variety of
input documents about Industrial User pretreatment compliance. Inputs will
include: Industrial Waste Surveys and updates, Sampling Reports, IU
Inspections, Baseline Monitoring Reports, Periodic Compliance Reports, Notices
of Slug Loadings, etc. Most of these inputs do not currently have standard
formats. Some of these IU input documents will have to be standardized over
the next several years in order to support a consistent tracking system.
As with Step 1, Step 2 will be designed and implemented as an enhancement
to the the current Permit Compliance System (PCS), as illustrated in Exhibit
III-l. PCS data files and software will be adapted to track Industrial User
-------
III-2
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III-3
data in formats similar to the current NPOES data. No new logical data files
will be added to PCS in Step 2. Only those pretreatment data types which
correspond to PCS data will be tracked. Fortunately, there are many
similarities between tracking POTW discharge compliance and IU pretreatment
compliance. Some data, however, such as production based limits, may be
difficult to track in Step 2.
Since the total number of Industrial Users is very large, tracking all of
them could seriosly impair PCS operations and performance. Therefore, only a
limited number of Industrial Users should be tracked. Only those Categorical
lUs where the State or Region acts as the Control Authority should be entered.
It is estimated that approximately 1,500 Categorical Industrial Users would be
tracked. The State and Regional Approval Authorities will determine the
amount of data to be tracked for each IU.
Step 2 will provide standard and user-designed (Quick Look) reports to
help EPA Headquarters, Regions, and participating State Approval Authorities
oversee the permits and enforcement actions of POTWs. It will also allow
Approval Authorities to directly monitor the compliance of those Industrial
Users for which It acts as Control Authority. PPETS users will be able to
request reports with statistics on a National, Regional, State, POTW, and IU
level.
Step 2 will be developed after Step 1 has been fully implemented and
integrated into EP,A operations. Development will occur when the National
Pretreatment Program is more fully established and when an automated system
for IU pretreatment data will benefit EPA Regions and delegated States.
-------
III-4
Step-2 Input Data
The Step 2 PPETS system will rely on several types of input documents to
provide Industrial User pretreatment data. These documents include:
• Industrial Waste Surveys and updates
• Control Authority Sampling Reports
• Control Authority Inspections of Industrial Users
• Baseline Monitoring Reports (BMRs) and Final Compliance Reports
• IU Periodic Compliance Reports
• Notices of Slug Loading.
The Industrial Waste Survey (IMS) is developed by Control Authorities to
identify Industrial Users and characterize the IU wastewater discharges in
their respective jurisdictions. The IWS must be maintained and updated
regularly. It is important for determination of the nature and quantity of
pollutants entering the POTW, identification of changes in the Industrial User
population, issuance and modification of effective control mechanisms, and
prioritization of Industrial Users to enable Control Authorities to more
efficiently allocate resources and schedule pretreatment activities.
Sampling analyses and reports are conducted by Control Authorities on
Industrial User wastestreams. The Control Authority takes wastewater samples
and analyzes them for various effluent pollutants. These activities provide
data which can be used to directly determine compliance with applicable
pretreatment standards and to confirm the representativeness of the sampling
analyses reported in industrial self-mom'toring reports.
Control Authorities also conduct inspections of Industrial User
facilities. These inspections generally examine information such as sampling
locations, pretreatment equipment, spill control practices, water flow
schematics, process change, etc. Industrial inspections, if performed
properly, should form the information base for any subsequent enforcement
action against Industrial Users.
-------
III-5
In the months following the establishment of categorical pretreatment
standards, affected Categorical Industrial Users must submit compliance
reports to the responsible Control Authority. A Baseline Monitoring Report
(BMR) must be submitted within 180 days after the effective date of the
standard; this report must identify the IU, describe its operations and
discharges, and indicate whether the applicable standards are being met.
Within 90 days following the date for final compliance, the affected IU must
submit a Final Compliance Report indicating the nature and concentration of
all limited pollutants in the regulated discharges and the maximum daily flow
for these discharges; the report must also indicate whether the pretreatment
standards are being met consistently.
Periodic Compliance Reports describe the regulated waste discharges of
Categorical Industrial Users. They are submitted by the IU to the responsible
Control Authority at least twice a year. The report must indicate the nature
and concentration of pollutants in effluents which are limited by categorical
pretreatment standards. In addition, the report must include a record of
measured or estimated average daily flows for the reporting period.
Notices of Slug Loading are submitted by Industrial Users when any
pollutant is released in a discharge at a flow rate or concentration which
will cause interference with the operation of the treatment works. The IU
must immediately notify the Control Authority of any such occurrence.
EPA has issued- suggested formats only for sampling reports performed by
the Control Authority or Industrial User. Formats have not been issued for
the other reports. For this data to support a consistent tracking system,
formats and data requirements will have to be standardized.
-------
IiI-6
Step 2 Output Reports
Relevant and informative output reports will help encourage EPA,Regions
and delegated States to take full advantage of the Step 2 PPETS capabilities.
Beneficial outputs will probably result in more Industrial User data being
entered and greater utilization of the PPETS system.
As in Step 1, two current PCS reports, the Quick Look Report and the
Milestone Report, will.be especially useful to PPETS. The software for these
reports will have to be modified to accept the Step 2 Industrial User data.
In addition, 9 other IU reports will be developed from modifications to
current PCS software. They are:
•• IU Facility Report
• IU Compliance Forecast Report
t IU Compliance Forecast with Violations Report
• IU Limitations Summary Report
• IU Limitations Summary with Measurement Violations Report
• Industrial Monitoring Administrative Report
• Industrial Monitoring Administrative Report by Parameter
• IU Monitoring Report Package
• IU Mailing Labels.
The PPETS Industrial User data can also support seven new standard
reports, including:.
• Categorical IU Summary Noncompliance Report
• Categorical IU Summary Noncompliance Trend Report
• Categorical IU Effluent Parameter Noncompliance Report
t .Categorical IU Effluent Parameter Noncompliance Trend Report
• PPS Generation Report
• Pretreatment Permit Status Summary
• NPDES Discharge Violation Pretreatment Investigative Report.
-------
III-7
The above listings are only suggested output reports. Other reports and
applications of PPETS data can be developed when needs arise. The following
sections describe each of the suggested reports in greater detail.
Modified PCS Reports
1. IU Facility Report
The IU Facility Report provides a comprehensive look at the data for each
permitted Industrial User selected. It consists of one section of general
facility information and seven additional sections each of which may or may
not be selected to print. The seven sections are: compliance schedule and
compliance violation data, enforcement action data, IU inspections data,
parameter limits data, measurement violation data, pipe schedule data, and
permit event data. The report is analogous to the current PCS Facility
Report.
2. IU Compliance Forecast Report
The IU Compliance Forecast Report displays information for permitted
Industrial Users that have compliance schedule events due within a specified
time. This report lists the information from the Compliance Schedule data,
along with some background information from the Permit Facility data. The
report is analogous to the current PCS Compliance Forecast Report.
3. IU Compliance Forecast with Violations Report
The IU Compliance Forecast with Violations Report displays information for
permitted Industrial Users that have compliance schedule violation events
within a specified time frame. This report lists some information from the
Permit Facility data, the information from the Compliance Schedule data, and
-------
III-8
the associated information from the Compliance Schedule Violation data. The
report is analogous to the current PCS Compliance Forecast with Violations
Report.
4. IU Limitations Summary Report
The IU Limitations Summary Report displays information on Industrial User
discharge schedules and their related parameter limits. The report lists some
identifying information .from the Permit Facility data, the Pipe Schedule
information and the associated Parameter Limits. This report is analogous to
the current PCS Limitations Summary Report.
5. IU Limitation Summary with Measurement Violations Report
The IU Limitation Summary with Measurement Violations Report displays
information on discharge schedules and their related parameter limits,
measurement violations, and enforcement actions. The report lists information
from the Permit Facility data, Pipe Schedule and associated Parameter Limits
data, Measurement Violation data, and Enforcement Action data. This report is
analogous to current PCS Limitation Summary with Measurement Violations
Report.
6. Industrial Monitoring Administrative Report
The Industrial Monitoring Administrative Report identifies data reported
on IU monitoring forms which is due, overdue, or violative in any way. The
report lists the required sampling data due by outfall, limit type, and
monitoring period end date; gives the number of parameters on each monitoring
report; and summarizes the number of violations recorded for each parameter.
This report is analogous to the current PCS DMR Administrative Report.
-------
III-9
7. Industrial Monitoring Administrative Report by Parameter
The Industrial Monitoring Administrative Report by Parameter identifies
data reported on IU monitoring forms which is due, overdue, or violative in
any way. The report lists each parameter for each monitoring report and
describes the worst violation recorded for each parameter. This report is
analogous to the current PCS OMR Administrative Report by Parameter.
8. IU Monitoring Report Package
The III Monitoring Report Package prints monitoring report forms that can
be mailed to Industrial Users for completion. The package can also produce
gummed mailing labels, an error report for lUs not having Monitoring Reports
printed, and an optional printed list of the lUs for which Monitoring reports
were produced. This report package is analogous to the current PCS DMR
Package.
9. IU Mailing Labels
The system will have the capability of printing mailing labels for any of
the Industrial User addresses in PPETS. Labels can be printed with or without
the cognizant official's name. The IU Mailing Labels capability is analogous
to current PCS Mailing Label capabilities.
PPETS New Step 2 Standard Reports
10. Categorical. IU Summary Noncompliance Report
The Categorical IU Summary Compliance Report will provide summary
statistics about the number of Categorical Industrial Users which are in
noncompliance. The report will list out the number of noncompliant lUs by CFR
code and type of noncompliance.
-------
111-10
11. Categorical IU Summary Noncompliance Trend Report
The Categorical IU Summary Noncompliance Trend Report will provide summary
statistics about noncompliance trends for a class of Categorical Industrial
Users over a period of time (perhaps 5 years). PPETS users will specify the
CFR codes for the lUs they need to analyze. From these Industrial Users, the
report will 11st out the number in noncompliance along with the type of
noncompliance that occurred each year. Exhibit III-2 contains a sample format
of this report.
12. Categorical IU Effluent Parameter Noncompliance Report
The Categorical IU Effluent Parameter Noncompliance Report will provide
summary statistics about noncompliance with specific discharge parameters.
The report will list the number of Categorical Industrial Users grouped by CFR
code which are in noncompliance with specific effluent parameters. PPETS
users will specify the CFR codes and effluents they need to analyze. Exhibit
III-3 contains a sample format of this report.
13. Categorical IU Effluent Parameter Noncompliance Trend Report
The Categorical IU Effluent Parameter Noncompliance Trend Report will
provide summary noncompliance statistics for specific effluents over a period
of time (perhaps 5 years). The report will list the number of Categorical
Industrial Users which are in noncompliance with specific effluent parameters
for each year.
14. PPS Generation Report
The PPS Generation Report will produce a Pretreatment Performance Summary
report tabulated from those Industrial Users being tracked by PPETS.
-------
in-ii
CATEGORICAL IU SUMMARY NONCOMPLIANCE TREND REPORT
State: XXXXXXX
CFR Code for lUs: CCCCCC
Date: MM/DD/YY
Number of Industrial User Violations for:
Year
Year 1:
Year 2:
Year 3:
Year 4:
Year 5:
Number
of lUs
50
52
55
56
57
Discharge
Limits
10
12
14
15
15
Reporting
Requirements
15
12
10
8
7
Compliance
Schedules
12
11
9
7
6
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54
13
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EXHIBIT IIi-2
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111-13
15. Pretreatment Permit Status Summary
The Pretreatment Permit Status Summary will list the current status of
Industrial User pretreatment permits for a specified jurisdiction. The report
will include the number and types of control mechanisms issued and the number
of lUs operating with expired or without any control mechanisms.
16. NPDES Discharge Violation Pretreatment Investigative Report
The NPOES Discharge Violation Pretreatment Investigative Report will
analyze specific NPDES permit discharge violations. Users will identify a
specific POTW discharge violation that they want to investigate. PPETS will
check whether there were similar Industrial User pretreatment discharge
violations occurring around the same time in that jurisdiction. The report
will print out a listing of these relevant pretreatment violations to help the
user determine whether there may have been a cause-and-effect relationship.
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111-14
0. Step 2 File Structure
Step 2 should not require any new data files to be added to PCS. Instead,
existing PCS may need to be modified to track Industrial User data. PCS files
that may require modification include:
• Permit-Facility Data File
• Compliance Schedule Data File
• Compliance Schedule Violation Data File
• Enforcement Action Data File
• Pipe Schedule Data File
• Parameter Limits Data File
0 Measurement Violation Data File
§ Inspection Data File
• Permit Event Data File.
Exhibit III-4 illustrates the PCS file structure modifications for Step 2.
There are many similarities between current NPDES data and Industrial User
pretreatment data. Many of the data elements can be used for pretreatment
tracking with no modifications. Some other elements may require broader
definitions and some descriptive codes may require additional values. Some
PCS data elements will not be used by PPETS.
Step 2 will also require some new data elements and modifications to some
current PCS data elements. The most important change will be developing an
Industrial User number to serve as a common key. In the final design, each IU
tracked may have to be assigned a unique identification number. This number
could be stored in the NPDES Number field of the IU data records. A new
'Receiving POTW field may have to be created to indicate the facility where
the Industrial User discharges.
Although EPA Regions and participating State Approval Authorities will
only track those Industrial Users for which they act as Control Authority,
they will decide for themselves the amount of data that should be entered. It
-------
111-15
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111-16
is estimated that PPETS will track pretreatment data for up to 1500
Categorical Industrial Users.
-------
111-17
Step 2 Software Functions
Step 2 will require some modification to PCS software routines. Several
PCS programs will have to be modified including:
• PCS Edit Program
• PCS-ADE Program
t PCS Update Program
• PCS Retrieval Reports
• PCS Sequential File Extract
• PCS Archival Procedures.
Since Step 2 will require modifications to many PCS data files, there will
have to be corresponding changes to the PCS-ADE, Edit, and Update programs.
Industrial User data is in many ways conceptually different from NPDES
discharge data; some of the data fields will be similar, but some will not be.
Therefore, it is suggested that the PCS-ADE and Edit programs have different
software modules for the entry and update of NPDES and pretreatment data.
Separate software modules could provide different prompts and responses for
different data, and thus make the system more user-friendly.
Step 2 will require modification to current PCS retrieval reports. As
with Step 1, the Quick Look and Milestone reports will be especially useful
for analyzing PPETS .data. In addition, the other current PCS standard reports
will have to be modified to support Industrial User data. New software will
be required to implement the suggested Step 2 standard reports previously
described. The PCS retrieval reports will be able to combine data for both
POTW facilities and Industrial Users.
The PCS Sequential File Extract will have to be modified for Industrial
User data. Th-is will allow Regions and States the option of downloading data
to local systems for specialized reporting.
The PCS archival procedures may also have to be revised for Step 2. The
Industrial User data may be given a different archival schedule than the
current PCS NPDES data.
-------
111-18
All of the above software modifications will have to include transaction
auditability data to record system usage. In the event of problems, this data
could trace system usage to help resolve difficulties. As with the current
PCS system, the PPETS transaction data will have to be obtained from the PCS
User Support Staff.
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111-19
F. Step 2 Data Element Listing
The Step 2 data elements will be mostly current PCS data elements. There
are many similarities between Industrial User pretreatment data and PCS NPDES
data.
Exhibit III-5 lists the data elements that will be useful for tracking
Industrial User data. Many of these elements are PCS elements, although some
elements will require broader definitions and some codes will require
additional values. There-are also many PCS elements that are not relevant for
pretreatment tracking; these are not included on the list.
The most important change to PCS files will be an Industrial User Number
to serve as a common key. Each IU tracked will have to be assigned a unique
number which can be stored in the NPDES Number data field. In addition, a new
'Receiving POTW field may have to be added to the Permit-Facility data file
to indicate where the Industrial User discharges.
Many PCS data elements can easily be adapted for pretreatment tracking.
For example, there are a set of data elements that track the submission of
DMRs. These elements can be used to track Industrial User monitoring reports;
they are listed in the exhibit under their PCS name. Also, some new elements
may need to be added to the PCS files, such as CFR Code.
There are many PCS data elements which may be applicable to pretreatment
in some cases, but will probably not be used for most Industrial Users. Some
examples include seasonal limits and report designation numbers. The data
element list includes many elements that will probably be used only
occassionally.
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111-20
STEP 2 DATA ELEMENTS
Data Element Name
Data Type
* NPDES Number / Industrial User Number
* Compliance Schedule Comments
* Compliance Schedule Number
* Compliance Schedule File Number
* Data Source Code
* Compliance Schedule Actual Date
* Compliance Schedule Report Received Date
* Compliance Schedule Date
* Compliance Schedule Event Code
* Compliance Schedule User Data Element 1
* Compliance Schedule User Data Element 2
* Compliance Schedule Violation Date
* Compliance Schedule Violation Event Code
* Compliance Schedule Violation Code
* Compliance Schedule Violation User Data Element 1
* Compliance Schedule Violation User Data Element 2
* Compliance Schedule Violation Comments
* Compliance Violation Compliance Schedule Number
* Violation Date - CV or MV
* Compliance Schedule Violation Data Source Code
* Compliance Schedule Violation-Date Resolved
* Compliance Schedule Violation-Date Scheduled
* Enforcement Action Response Achieved Date
* Enforcement Action Comment
* Enforcement Action- NPDES/IU Number CV Key
* Enforcement Action Compliance Schedule Violation Code
* Enforcement Action Compliance Schedule Violation Date
* Enforcement Action NPDES/IU Number MV Key
* Enforcement Action Modification Number
* Enforcement Action Code
,* Enforcement Action Date
* Enforcement Action Status Code
* Enforcement Action Person Initiating
* Enforcement Action Response Due Date
* Enforcement Action File Number
* Enforcement Action Status Date
* Enforcement Action Season Number
* Enforcement Action Data Source Code
* Enforcement Action Violation Recognition Date
* Enforcement Action Discharge Number
Common Key
Compl iance-Schedul e
Compliance-Schedule
Compl i ance-Schedu 1 e
Compliance-Schedule
Compl i ance-Schedu 1 e
Compl i ance-Schedu 1 e
Compl i ance-Schedu le
Compl i ance-Schedu 1 e
Compl i ance-Schedu 1 e
Compliance-Schedule
Compl i ance-V i o 1 at i on
Compliance-Violation
Compliance-Violation
Compliance-Violation
Compl i ance-Vi ol at i on
Compliance-Violation
Compliance-Violation
Compliance-Violation
Measurement-Violation
Compliance-Violation
Compl i ance-Vi ol ati on
Compliance-Violation
Enforcement-Act i on
Enforcement-Action
Enforcement-Act i on
Enforcement-Act i on
Enforcement-Action
Enforcement-Act i on
Enforcement-Act i on
Enf orcement-Acti on
Enforcement-Act i on
Enforcement-Act i on
Enforcement-Action
Enf orcement-Acti on
Enforcement-Action
Enforcement-Action
Enforcement-Act i on
Enforcement-Action
Enforcement-Action
Enforcement-Action
* Data Element Already Stored in PCS
EXHIBIT III-5
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111-21
Data Element Name
Data Type
* Enforcement Action Event Code
* Enforcement Action Limit Type - Alphabetic
* Enforcement Action Limit Type - Numeric
* Enforcement Action Monitoring Date
* Enforcement Action Monitoring Location
* Enforcement Action Parameter Code
* Enforcement Action Compliance Schedule Number
* Enforcement Action Violation Type
* Inspection Date
* Inspected Facility Type
* Inspection Comments
* Inspector Code
* QA Data-Based Inspection
* Inspection User Data Element 1
* Inspection User Data Element 2
* Inspection Type
* Measurement /Viol at ion Concentration Average
* Measurement/Violation Concentration Minimum
* Measurement/Violation Concentration Maximum
* Measurement/Violation Quantity Average
* Measurement/Violation Quantity Maximum
* Measurement/Violation Monitoring Period End Date
* Violation Code-Measurement
* No Discharge Indicator
* Reported Concentration Unit
* Reported Number of Excursions
* Reported Frequency of Analysis
* Reported Sample Type
* Reported Quantity Unit
* Measurement Violation Percent - Concentration Average
* Measurement Violation Percent - Concentration Minimum
* Measurement Violation Percent - Concentration Maximum
* Violation Date - CV or MV
* Measurement/Violation Report Designator
* Measurement/Violation Discharge Number
* Measurement/Violation Percent - All
* Measurement/Violation Limit Type
* Measurement/Violation Monitoring Location
* Measurement/Violation Modification Number
* Measurement/Violation Parameter
* Measurement Violation Percent Quantity Average
* Measurement Violation Percent Quantity Maximum
* Measurement/Violation Season Number
* Measurement Violation - Worst Case
* Seasonal DMR Printing Indicators (Limit) .
* Contested Parameter Indicator
* Limit User Data Element 1
Enforcement-Action
Enforcement-Action
Enforcement-Action
Enforcement-Act ion
Enforcement-Action
Enforcement-Act i on
Enforcement -Act ion
Enforcement-Act ion,
Inspection
Inspection
Inspection
Inspection
Inspection
Inspection
Inspection
Inspection
Measurement-Vi o 1 at i on
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement- V i ol at i on
Measurement- V i ol at i on
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement-V i o 1 at i on
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement-Violation
Compl i ance-Viol ati on
Measurement-Viol ation
Measurement-Violation
Measurement-Vi o 1 at i on
Measurement-V i ol at i on
Measurement-Violation
Measurement-Violation
Measurement-Viol ation
Measurement-Violation
Measurement-Violation
Measurement-Violation
Measurement-Violation
Parameter-Limits
Parameter-Limits
Parameter-Limits
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111-22
Data Element Name
Data Type
* Limit User Data Element 2
* Limit User Data Element 3
* Modification Period End-Date
* Modification Period Start Date
* Frequency of Analysis
* Archive PL Key
* Concentration Average Limit
* Concentration Minimum Limit
* Concentration Maximum Limit
* Concentration Average Limit Standard
* Concentration Unit Code Standard
* Concentration Minimum Limit Standard
* Concentration Maximum Limit Standard
* Concentration Unit Code
* Limit Type - Numeric
* Quantity Average Limit
* Quantity Maximum Limit
* Quantity Average Limit Standard
* Quantity Unit Code Standard
* Quantity Maximum Limit Standard
* Quantity Unit Code
* Limit Type - Alphabetic
* Monitoring Location
* Modification Number
* Limit Discharge Number
* Limit File Number
* Parameter Code
* Sample Type
* Season Number
* Statistical Base Code
* Standards Basis
* Application Complete Date
* Application Received Date
* Permit Date Effective
* Permit Date Issued
* Permit Date Expired
* Public Notification Date
* Permit Tracking Actual Date
* Permit Tracking Comment
* Permit "Track ing Event Code
* Permit Tracking. Date Scheduled
* Permit Tracking User Data Element 1
* Permit Tracking User Data Element 2
Receiving POTW NPDES Number
* Archival Indicator
* Archival Date
CFR Code
* Categorical Industry Indicator
* City Name
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter- Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter- Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Parameter-Limits
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Event
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
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111-23
Data Element Name
Data Type
* City Code
* County Name
* County Code
* Operator Name
* Operator Address - City Name
* Engineer
* Operator Address - State Code
* Operator Street Address Line 1
* Operator Street Address Line 2
* Operator Telephone Number
* Operator Address - Zip Code
* Federal Facility Identification Number
* Latitude
* Final Limits Indicator
* Latitude/Longitude Code of Accuracy
* Longitude
* Facility Name
* Facility Inactive Code
* Facility Inactive Date
* Primary Industry Category
* Primary Mailing City
* Primary Mailing Name
* Major Rating Code
* Primary Mailing State
* Primary Mailing Street Line 1
* Primary Mailing Street Line 2
* Primary Mailing Zip Code
* Needs Suffix
* Owner Address - City Name
* Cognizant Official
* Owner Name
* Original Permit Issue Date
* Owner Address - State Code
* Owner Street Address Line 1
* Owner Street Address Line 2
* Owner Telephone Number
* Owner Address - Zip Code
* Permit Type Indicator
* Re issuance Control Indicator
* Facility Location City
* Facility User Data Element 1
* Facility User Data Element 2
* Facility User Data Element 3
* Facility User Data Element 4
* Facility User Data Element 5
* Facility User Data Element 6
* Facility User Data Element 7
* Facility User Data Element 8
* Facility User Data Element 9
* Facility User Data Element 10
* Region Code
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Perm it- Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
-------
111-24
Data Element Name
Data Type
* Reissued Number
* Facility Location Name
* Facility Location State
* Facility Location Street Line 1
* Facility Location Street Line 2
* Facility Location Telephone Number
* Facility Location Zip Code
* SIC Code 1972 Facility Description
* State Permit Number
* State Code
* Sub-Region Code
* Cognizant Official Telephone
* Type of Application
* Agency Reviewer
* Seasonal DMR Printing Indicators (Pipe)
* Final Limits Start Date
* Final Limits End Date
* Archive PS Key
* Initial Limits Start Date
* Initial Limits End Date
* Minimum Number of DMR Lines
* Interim Limits Start Date
* Interim Limits End Date
* Total Number of Reports Due
* Number of Units in Report Peri ode
* Next DMR Submission Due Date
* Number of Units in Submission Period - EPA
* Number of Units in Submission Period - State
* Pipe Inactive Code
* Pipe Inactive Date
* Pipe Description
* Pipe Latitude
* Pipe Lat/Long Code- of Accuracy
* Pipe Longitude
* Pipe User Data Element 1
* Pipe User Data Element 2
* DMR Form Comments
* Reporting Units
* Initial Report Date
* Initial Submission Date - EPA
* Initial Submission Date - State
* DMR Forecasting Submission Date - Both
* DMR Forecasting Submission Date - EPA
* DMR Forecasting Submission Date - State
* Submission Unit - EPA
* Submission Unit - State
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility'
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Permit-Facility
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
•Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
P.ipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
Pipe-Schedule
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