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
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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
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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.
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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
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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,
                                   2-8

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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
                                 3-1

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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
                              3-2

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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
                                 3-3

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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
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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
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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
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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
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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.
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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.
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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
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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).
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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.
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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

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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

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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

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                  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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                         1-9

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                                                                             1-10
                               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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                               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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                                                                           II-9

    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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                                                                          11-12
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.

-------
                                                                                                              11-13
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                                                                      '   11-14

    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

-------
                                                                           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

-------
                                                                           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

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                                                                           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

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                                                                         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.

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                                                                           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

-------
                                                                          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.

-------
                                                                           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.

-------
                                                                              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

-------
                                                                            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

-------
                                                                              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.

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                                                                               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

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                                                                              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)

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                                                                              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.)

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                                                                              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)

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PART IV:  PRETREATMENT PERMITS AND ENFORCEMENT TRACKING SYSTEM
                    INITIAL SYSTEM DESIGN

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                                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

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                                                                                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.

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1-3

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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

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                                                                              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.

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                                                                             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

-------
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                                                                        11-15  .

 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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                                                                         11-18
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.
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.

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                                                                          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.

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                                                                          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.

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                                                                        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
5 Yr Avg
  54
   13
     10
                                 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.

-------
                                                                         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
Ed
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             I
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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.

-------
                                                                           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.

-------
                                                                            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

-------
                                                   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

-------
                                                   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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