Environmental Protection
Agency
Office of Drinking Water
ussi
\
*A /
^ PRO^
[Feasibility Study and System
Design for the Underground
Injection Control Program
June 26, 1978
Arthur Young & Company
-------
Arthur Young & company
1025 CONNECTICUT AVENUE. N. W.
WASHINGTON. D. C. 20036
June 26, 1978
Mr. Frederick T. Martin, Project Officer
Office of Drinking Water
Environmental Protection Agency
Waterside Mall
401 M Street, SW
Washington, D.C. 20760
Reference: Contract No. 68-01-4640
Subject : Final Report
Dear Mr. Martin:
Arthur Young & COmpany is pleased to submit, in final form,
our Feasibility Study Report for the Underground Injection Control
Information System. This report includes definition of the informa-
tion requirements of the Office of Drinking Water, the Regions
and the States, a presentation of alternative concepts, and a
discussion of the recommended approach. Comments received from
the working group have been incorporated as appropriate.
Should you have any questions regarding the report, please
contact Dr. Donald Fitzpatrick or me at (202) 785-4747.
Directive of Work 4640-7
Very truly yours
ARTHUR YOUNG & COMPANY
By: &£ ^
Gerald Mendenljall
Partner
Enclosure
cc: Mr. Edward Franklin,
MIDSD Project Officer
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TABLE OF CONTENTS
PAGE
MANAGEMENT SUMMARY
1. Underground Injection Control Informa- 1-2
tion System Requirements
2. Summary of Current Issues and Evaluation 1-5
Criteria
3. Alternative System Concepts and 1-7
Implementation Strategies
4. Cost Effectiveness Analysis 1-9
5. Recommendations 1-13
II. REQUIREMENTS ANALYSIS
1. Background II-l
2. Information Requirements II-8
3. Issues Affecting UIC Program Data 11-13
Management
4. Evaluation Criteria 11-15
III. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE
SYSTEM CONCEPTS
1. UIC Management Information System III-1
Activities
2. UIC Management Information System - III-3
Alternative 1
3. UIC Management Information System - III-7
Alternative 2
4. UIC Management Information System - III-9
Alternative 3
5. UIC Management Information System - 111-12
Alternative 4
6. UIC Management Information System - 111-14
Alternative Implementation Strategies
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TABLE OF CONTENTS (cont'd)
PAGE
COST
ANALYSIS
1.
General Assumptions
IV-1
2.
Cost Strategy
IV-6
3.
Cost Matrices
IV-7
4.
Alternative Workload Assumptions
IV-9
5.
Alternative Cost Analysis
IV-10
6.
Effectiveness Analysis of Alternatives
IV-22
7.
UIC System Concept Recommendation
IV-2 5
8.
Alternative System Implementation
Approaches
IV-2 5
RECOMMENDATIONS
1.
Recommended UIC System Activities
V-l
2.
System Description
V-14
3.
Implementation Plan
V-l 6
4.
UIC Federal Reporting System
V-22
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LIST OF EXHIBITS
FOLLOWS
PAGE
1-1 UNDERGROUND INJECTION CONTROL PROGRAM 1-2
INFORMATION REQUIREMENTS OVERVIEW
1-2 UNDERGROUND INJECTION CONTROL INFORMATION 1-4
SYSTEM FUNCTIONAL DESCRIPTION SUMMARY
1-3 UIC INFORMATION SYSTEM DESIGN ALTERNATIVES 1-7
1-4 FIXED COST LIFE CYCLE COST SUMMARY 1-10
1-5 LIFE CYCLE IMPLEMENTATION AND OPERATIONS 1-10
COST SUMMARY
1-6 GRAPH OF IMPLEMENTATION AND OPERATION 1-10
COSTS FOR AN ADMINISTRATIVE AGENCY
1-7 ALTERNATIVES I THROUGH IV, TOTAL COST 1-11
1-8 SCEMAROPS FPR CENTRALIZATION VS DISTIBUTED 1-13
IMPLEMENTATION ALTERNATIVES
1-9 ALTERNATIVE SCENARIOS LIFE CYCLE COST 1-13
PROJECTIONS
I-10 UIC MANAGEMENT INFORMATION SYSTEM 1-14
IMPLEMENTATION PLAN
II-l UIC PROGRAM INFORMATION REQUIREMENTS II-8
OVERVIEW
II-2 UIC PROGRAM INFORMATION REQUIREMENTS AND II-9
PROCESSING FLOW - ADMINISTRATIVE STATE
OR REGION
II-3 UIC PROGRAM INFORMATION REQUIREMENTS AND
PROCESSING FLOW - PROGRAM MONITORING REGION 11-11
II-4 UIC PROGRAM INFORMATION REQUIREMENTS AND
PROCESSING FLOW - EPA NATIONAL HEADQUARTERS 11-12
III-l UNDERGROUND INJECTION CONTROL INFORMATION
SYSTEM PRELIMINARY FUCTIONAL DESCRIPTION III-l
III-2 UIC INFORMATION SYSTEM - DESIGN ALTERNATIVE 1 III-3
III-3 UIC INFORMATION SYSTEM - DESIGN ALTERNATIVE 2 III-7
-------
LIST OF EXHIBITS (Cont'd)
FOLLOWS
PAGE
III-4 UIC INFORMATION SYSTEM - DESIGN ALTERNATIVE 3 111-10
III-5 UIC INFORMATION SYSTEM - DESING ALTERNATIVE 4 111-12
III-6 UNDERGROUND INJECTION CONTROL SYSTEM 111-14
PROCESSING CONFIGURATIONS
IV-1 ASSUMPTIONS REGARDING SYSTEM DEVELOPMENT IV-2
AND OPERATIONS COST
IV-2 SYSTEM DESIGN & DEVELOPMENT COSTS - IV-7
BLANK FORM
IV-3 IMPLEMENTATION & OPERATIONS COST - IV-7
BLANK FORM
IV-3A ALTERNATIVE SYSTEM CONCEPTS COST ANALYSIS IV-8
IV-4 SYSTEM DESIGN & DEVELOPMENT COSTS - IV-12
ALTERNATIVE 1
IV-5A,B,C SYSTEM IMPLEMENTATION AND OPERATION COST - IV-12
ALTERNATIVE I - SMALL STATE, LARGE STATE,
FIXED COST
IV-6 SYSTEM DESIGN & DEVELOPMENT - ALTERNATIVE II IV-14
IV-7 SYSTEM IMPLEMENTATION & OPERATION COSTS - IV-14
ALTERNATIVE II - SMALL STATE, LARGE STATE,
FIXED COST
IV-8 SYSTEM DESIGN & DEVELOPMENT COSTS - IV-15
ALTERNATIVE III
IV-9A,B,C SYSTEM IMPLEMENTATION & OPERATION COSTS - IV-15
ALTERNATIVE III - SMALL STATE, LARGE STATE,
FIXED COST
IV-10 SYSTEM DESIGN & DEVELOPMENT COST - IV-16
ALTERNATIVE IV
IV-11A,B,C SYSTEM IMPLEMENTATION & OPERATION COST - IV-16
ALTERNATIVE IV - SMALL STATE, LARGE STATE,
FIXED COST
IV-12 SYSTEM IMPLEMENTATION & OPERATIONS - IV-16
ALTERNATIVE III, FIXED COST
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LIST OF EXHIBITS (Cont'd)
IV-13
IV-14
IV-15
IV-16
IV-16A
IV-17
IV-18
IV-19
IV-20
IV-21
IV-2 2
IV-2 3
V-l
V-2
V-3
V-4
V-5
V-6
V-7
FOLLOWS
PAGE
SYSTEM IMPLEMENTATION & OPERATIONS - IV-16
ALTERNATIVE III, ADMINISTRATIVE AGENCY
TOTAL COST - ALTERNATIVE III, LARGE STATE IV-17
IMPACTS OF SYSTEM ALTERNATIVES IV-19
IMPACTS OF CENTRALIZATION VS DISTRIBUTED IV-2 3
IMPLEMENTATION ALTERNATIVES
ALTERNATIVE IMPLEMENTATION STRATEGIES IV-25
COST ANALYSIS
SYSTEM IMPLEMENTATION AND OPERATION COST IV-25
ESTIMATES - ALTERNATIVE III - DISTRIBUTED, SMALL
SYSTEM IMPLEMENTATION AND OPERATION COST IV-25
ESTIMATES - ALTERNATIVE III - DISTRIBUTED, LARGE
SYSTEM DESIGN AND DEVELOPMENT COST ESTIMATES - IV-25
ALTERNATIVE III - DISTRIBUTED
SYSTEM IMPLEMENTATION AND OPERATION COST IV-25
ESTIMATES - ALTERNATIVE III - DISTRIBUTED,
FIXED COST
LIFE CYCLE IMPLEMENTATION AND OPERATIONS IV-25
COST SUMMARY
SCENARIOS FOR CENTRAL VS DISTRIBUTED IV-25
ALTERNATIVE IMPLEMENTATIONS
ALTERNATIVE SCENARIOS LIFE CYCLE COST IV-26
PROJECTIONS
UIC INFORMATION SYSTEM DESIGN ALTERNATIVE III V-2
UIC INFORMATION SYSTEM REPORTS V-2
TRACK PERMIT APPLICATIONS AND MAINTAIN PERMIT V-2
MAINTAIN UIC OPERATIONS INVENTORY V-4
DEVELOP AND TRACK INSPECTION SCHEDULE V-5
SCREEN AND MAINTAIN SELF-MONITORING REPORTS V-7
ANSWER SPECIAL INQUIRIES V-8
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LIST OF EXHIBITS (Cont'd)
FOLLOWS
PAGE
V-8 SCREEN AND MAINTAIN INSPECTION FINDINGS V-9
V-9 INITIATE AND TRACK ENFORCEMENT ACTIONS V-ll
V-10 ANALYZE PROGRAM EFFECTIVENESS V-12
V-ll PERMITTEE DATA FILE V-14
V-12 INVENTORY DATA FILE V-14
V-13 VIOLATIONS AND COMPLIANCE DATA FILE V-15
V-14 UIC MANAGEMENT INFORMATION SYSTEM V-16
IMPLEMENTATION PLAN
V-15 UIC FEDERAL REPORTING SYSTEM FUNCTIONAL V-22
DESCRIPTION
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I. MANAGEMENT SUMMARY
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I. MANAGEMENT SUMMARY
The Environmental Protection Agency (EPA) is responsible for the
Underground Injection Control (UIC) Program as defined in Subtitle C
of the Safe Drinking Water Act of 1974. This program is intended to
protect underground sources of water, groundwater, from the subsurface
emplacement of fluids by industry. The Office of Drinking Water (ODW)
of EPA is currently in the process of finalizing regulations for
implementation of the UIC Program. These regulations will establish
minimum requirements for effective State programs to prevent
underground injection practices which endanger underground sources of
drinking water. Included in these regulations will be the definition
of the roles of EPA Headquarters and Regions, the States, other Federal
agencies, and industry.
The Office of Drinking Water recognized early in the regulatory
process that automated systems would probably be required to
effectively handle the data management aspect of the program. This
feasibility study was initiated to ensure that operational data
management systems would be available for both States and Regions to
assist them in the implementation of the regulations. The specific
objectives of the study are as follows:
Recommend a system concept which incorporates the
requirements of each of the major participants in the
Underground Injection Control Program; EPA Headquarters, the
EPA Regional Offices, and the States administering the
prog ram
Define an implementation strategy which accommodates both
the immediate needs for implementation of the program and
the longer range requirements for program management and
enforcement activities
Assess the impact of the developing regulations on the costs
and operations of the Underground Injection Control
Information System
Establish the cost/effectiveness of recommended system
concepts and implementation strategies
Provide a firm foundation for the development of general
and detailed designs for the recommended system concept.
The specific purpose of the Underground Injection Control Information
System is to provide a capability for the operational management of
the program in the administering authority, either the authorized State
or the EPA Region. However, this system definition also includes
interfaces to a Federal Reporting System which would support the EPA
Regions and EPA Headquarters in their program monitoring role.
1-1
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The achievement of the objectives of this study depends on the
ability to provide structure to a system in the context of the
development of regulations for the Underground Injection Control
Program. This is the case in any new program area. To assist in the
definition of the system objectives, and to ensure that the specific
needs of the Regions and States were considered, their active
participation was solicited through their representatives in a UIC
Information System Working Group. Although there continue to be many
unresolved areas in the regulations which will have an impact on
detailed design of the Underground Injection Control System, we believe
that EPA's significant efforts in the regulatory process and
participation of the Working Group has resulted in sufficient
definition to continue toward the general design of a UIC Information
System.
In the following sections of this Management Summary, we present
our analysis of the requirements of various participants in the
Underground Injection Control Program, a summary of current issues and
evaluation criteria, alternative system concepts and implementation
strategies for the system, a cost/effectiveness analysis for each of
these alternatives and, finally, recommendations for an Underground
Injection Control Information System. These topics are treated in
more detail in the body of the report.
1. UNDERGROUND INJECTION CONTROL INFORMATION SYSTEM REQUIREMENTS
The Underground Injection Control Information System must support
the requirements of each of the participants in the Underground
Injection Control Program. An overview of these requirements is
presented in Exhibit 1-1.
As indicated in the exhibit, the role of EPA Headquarters is
primarily one of oversight. EPA is required by legislation to obtain
an inventory of underground injection operations for those States for
which an Underground Injection Control Program is necessary to assure
that underground injection will not endanger drinking water sources.
States which the Administrator of EPA believes require such a program
will be designated and included in the inventory. In addition to the
inventory, EPA will provide a monitoring role of the National UIC
Program status via required annual reports from the designated States.
Such reports are anticipated to include summaries of inventory
adjustments, violations, enforcement actions and other program
management information.
The EPA Region will either act as a program monitor or the
administrator of the program in a designated State, depending upon
whether or not the State has accepted primacy. In its role as program
monitor, the EPA Region would be required to maintain an inventory of
underground injection wells. The Region would also act on behalf of
the Administrator of EPA in monitoring the status of the State programs
within the Region through required periodic reports.
1-2
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DELGATED
STATES ,
ADMINISTERING
REGIONS
UNDERGROUND INJECTION CONTROL PROGRAM
INFORMATION REQUIREMENTS OVERVIEW
EPA REGION -PROGRAM MONITOR
INVENTORY INFORMATION
Activo Operation
Ownership
Location
Operation Classification
Number of Wells, Holes, etc.
Permit Number
Permit Statu*
Permit Criteria
. . Pressures
. . Volumes
. . Amounts
. . etc
Inactive Operation
Archival Information
. . Ownership
. . Classification
. . Location
. . Number of Wells, Holes, etc.
. . Status
Inspection Findings
. . Plugged
.. Abandoned
. . Permit/Affidavit Number
Summary Information
Actives, Inactive*
Operation Classification
INITIAL
INVENTORY INFORMATION
State by State
Active Operations
. . Ownership
. . Location
.. Status
Inactive Operations
. . Ownership
. . Location
.. Status
Regional Summary
Actives, Inactive*
Operation Classification
ANNUAL
>
ZY
I rs
INITIAL
EPA NATIONAL HEAOQUARTERS
NATIONAL INVENTORY
Region by Region
Active Operations
Inactive Operations
National Total*
Active
. . Classification
. . Status
Inactive
. . Plugged
.. Abandoned
. . Shutdown
. . olc.
Regional Inventory Adjustments
New Operations
. . Ownership, Location, Classification
Shutdown Operations
. . Ownership, Location, Classification
Abandoned Operations
. . Ownership, Location. Classification
COMPLIANCE INFORMATION
e Permil Information
Ownership & Location
Permit Number
Permit Status
Permit Criteria
. . Pressures
. . Volumes
Compliance Schedule
Scheduled Inspections
Inspection Findings
e Violations
Type & Severity
Dale of Violation
Location of Violation
ENFORCEMENT ACTIONS
Violation Type & Severity
Enforcement Action
Action Type
Action Date
Action Status
Action History
PERIODIC
V
COMPLIANCE SUMMARY
Stato by State
Violation Totals
- ¦ Typo
. . Severity
. . Dato
Inspection Totals
. . Scheduled
. . Conducted
. . Violation Detected
. . Inspection Follow-up
ENFORCEMENT SUMMARY
Slate by State
Enforcement Actions
. . Violation
. . Action Type
. . Action Status
REGIONAL SUMMARY
' Number of Incidents of
Non-Compliance
Number of Enforcement Actions
Total Inventory Adjustments
ANNUAL
ANNUAL REPORT
Inventory Adjustments Summary
New Operations
Shutdown Operations
. . Plugged
. . Permit Revoked
. . etc.
Abandoned Operations
Violations Summary
National
Regional
States
Enforcement Actions Summary
National
Regional
Stales
Regulations Subpart F
Progress
Disposal, Rechatge Wells
m
X
I
-------
The active administration of the UIC Program in a designated
State may be either by the State, if it has been authorized by the
Administrator, or by the Region. This role includes:
The development and maintenance of an inventory of
underground injection wells in the State for both active
and inactive operations
The issuance and maintenance of permits for underground
injection operations
The monitoring of underground injection operations via
operator self-monitoring reports, scheduled site inspections
and other compliance monitoring
The initiation of enforcement actions where lack of
compliance is identified.
The primary purpose of the Underground Injection Control
Information System is the support of the administering organizations,
whether State or Region. However, the information system requirements
for support of the EPA's National and Regional monitoring requirements
have been included in the recommendation for a Federal Reporting
System. In the remainder of this section we will focus on the former
requirements, the support for the administering organization.
A functional definition of the Underground Injection Control
Information System is presented in Exhibit 1-2. The functional
definition is in terms of those activities the information system
would be required to support. These activities include:
Track permit applications and maintain permits - An
information system must track the permitting of a UIC
operation from the time an operator is identified, through
the application process, and, finally, the issuance of a
permit. Once the permit is issued, a system should support
maintenance of the data regarding permittees and their
changes in status.
Maintain UIC operations inventory - In response to EPA
requirements, a system must maintain an inventory of all UIC
operations. This must include both active and inactive UIC
operations.
Develop and track inspection schedules - Based on the
operations inventory and permit status, a system should
assist in the scheduling of inspections and the tracking of
those inspections for completion.
Screen and maintain inspection findings - The reports
submitted by the field inspectors should be screened for
data validity and analyzed with regard to other current
1-3
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system data for the UIC operator. They should then be filed
and maintained to provide a compliance history for the UIC
operator.
Screen and maintain self-monitoring reports - The UIC
operators are required to submit data from tests on their
ongoing operations, for example injection pressures, on self
monitoring reports. These reports should be screened against
the previous history of that operator's reports and permit
conditions, as appropriate. Exception reports should be
provided for the program support staff. This data should
be maintained in a history file for subsequent analysis.
Initiate and track enforcement actions - As possible
violations are identi fied through the various program
functions, Enforcement will need to initiate and track
enforcement actions regarding a UIC operator. A system could
assist in this process by maintaining schedule dates,
providing status tracking and continued compliance
moni to r ing.
Analyze program effectiveness - Each of the operational
activities provides information which can be used for
management reporting and program analysis. Such analysis
includes trends on numbers of UIC operations permitted,
violations, enforcement actions, inspections and other
program actions. Statistical data can also be obtained from
the operations inventory regarding the type of injection
operations, status and other operational data.
Answer special inquiries - In addition to the standard
reports required by EPA, program administration, and others;
there is a need to provide the ability to answer special
inquiries with regard to the program status. This might
include detailed information on the status of a particular
UIC operation or special reports for analysis of the program
status.
For each of these activities, the Underground Injection Control
Information System should provide the capability to receive, edit, and
maintain the information shown in Exhibit 1-2 and produce the
corresponding outputs. The UIC Program must be able to support all
of these requirements in one form or another. It is not clear, however,
that in the near term an automated system is required to support all
of these activities, nor that an automated system would provide the
most effective means of satisfying these requirements. The objective
of this study is to assess alternative approaches for meeting these
requirements, both in terms of cost and effectiveness. The specific
requirements of the program are presented in Chapter II of this report.
1-4
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UNDERGROUND INJECTION CONTROL INFORMATION SYSTEM
FUNCTIONAL DESCRIPTION SUMMARY
SOURCE DATA ACTIVITIES OUTPUT RECIPIENT
Tuck Pennil Application
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2. SUMMARY OF CURRENT ISSUES AND EVALUATION CRITERIA
During the analysis of the UIC Program requirements, we have
defined several issues which impact the eventual implementation and
operation of the proposed Underground Injection Control Information
System. The specific issues are as follows:
There are multiple agencies responsible for the
administration of the program within the States
The jurisdiction with regard to surface impoundments is not
resolved
The specific regulatory procedures and program
implementation approaches are being developed by ODW.
The first of these issues must be addressed by the States in
deciding how to administer the programs. The other issues are currently
being pursued by the Office of Drinking Water within EPA in the process
of developing the necessary regulations for the Underground Injection
Control Program. Although these issues will impact the detailed design
and implementation of the system, they have only minimal impact on the
current feasibility study. However, some assumptions have been made .
in the cost analysis regarding the implementation strategy of ODW and
the level of participation of the States. A more detailed presentation
of these issues is given in Chapter II of this report and the
assumptions are presented in the cost analysis of Chapter IV. The
issues are briefly summarized below:
(1) Multi-Agency Administration
In many States the UIC program involves more than one State
agency. These include the commissions which regulate oil and gas
production, departments of natural resources, State environmental
protection agencies, and various health and conservation groups.
This multiple agency administration complicates both the
operational requirements needed for a coordinated Underground
Injection Control Information System and the periodic reporting
required by EPA. EPA is encouraging identification of a single
source for the collection, dissemination and coordination of
information and program activities. However, the system design
must be responsive to the different State configurations and
differing agency requirements.
(2} Jurisdiction of Surface Impoundments
Originally pits, ponds and lagoons, known as surface
impoundments, were believed to be under the UIC Program. However,
this is currently under study by ODW, in conjunction with the
States, to better define the issues regarding surface
1-5
-------
impoundments. If surface impoundments are to be within
Underground Injection Control, the system would be required to
support these operations and their program responsibilities. The
impact on the system design is the need for flexibility in the
design to facilitate the inclusion of these areas in the future.
(3) Evolving Regulatory Environment
In many areas of the UIC program the basic procedures under
which the program would operate are still undefined, since ODW
is in the development stages of the regulatory process. The
undefined areas include:
Specific forms and data content have not been developed for
Federal permits and self-monitoring reports
Enforcement requirements have not been firmly established
The specific roles of EPA with regard to States has not been
established
The identification of designated States has not been
completed.
These issues have implications for the costing of the UIC Information
System which will be discussed in later sections of this report.
However, we do not believe these significantly impact the findings and
recommendations of this report, and merely reflect the normal
uncertainties involved in advanced planning.
These issues will require resolution prior to the detailed design.
Further, there should be continued consciousness by ODW of the impact
of the regulations on the design of operational systems to ensure that
the regulations are feasible in terms of their implementation. This
is particularly true with regard to the permitting process and its
relationship to self-monitoring. If self-monitoring is to be of use,
there is a need to define the values to be reported upon and these
should be consistent with permit conditions.
In addition to the issues, we have identified several criteria
for evaluation of the alternatives, both in terms of effectiveness and
efficiency. As discussed in Chapter II, these criteria include the
following :
The system should minimize the reporting burden imposed on
States and Regions in their administration of the program.
The system concept and its implementation should minimize
disruption of the State and Regional organizations. This
should include ease of use by program staff, and
compatibility with existing systems in terms of both
organizational structure and ADP capability.
1-6
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The system design should require a minimal level of technical
support for operation and maintenance.
The system must be reliable in terms of its edit and accuracy
control procedures, both for consistency and responsiveness
to the administrative authority.
The system must provide the flexibility to adapt to the
various organizational forms within the States, and to both
State and Regionally operated administration.
If operation of the system is to be in the States, the system
must be portable to minimize the cost of transfer to various
State ADP configurations.
The system must support the monitoring function of both EPA
Headquarters and EPA Regions with regard to the UIC Program..
These criteria will be used in the requirements analysis to assist in
an evaluation of each of the alternatives.
3. ALTERNATIVE SYSTEM CONCEPTS AND IMPLEMENTATION STRATEGIES
The alternatives for the Underground Injection Control
Information System include both alternative levels of automation in
support of the program and alternative implementation strategies. The
alternative levels of automation basically span the range from a
completely manual system to automation of each of the activities as
described in Section 1. The decision with regard to an implementation
strategy is whether or not EPA should implement and support a system
which is based in the States, that is a fully distributed system. This
approach would be similar to the one utilized by ODW in implementation
of the Model State Information System (MSIS). The alternative is to
provide a centralized service arrangement for Region and State use.
These alternatives are discussed in Chapter III of this report and
are presented briefly below.
The alternative levels of automation are presented in Exhibit I-
3. As indicated, the alternatives represent successively increasing
levels of automation with regard to each activity. The alternatives
are as follows:
Design Alternative 1 - This alternative is completely manual.
There would be no automated support for any of the system
processes and separate manual files would be required for
the permits, operations inventory, self-monitoring reports,
violation files and enforcement action files. The system
management would clearly be distributed at the administering
organization level, and all management reporting, data
management and processing would be manual.
1-7
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UIC INFORMATION SYSTEM
ALTERNATIVE SYSTEM CONCEPTS
MANUAL
BASIC REPORTING
LEVEL OF AUTOMATION
COMPLIANCE TRACKING
LEVEL OF AUTOMATION
DECISION SUPPORT
LEVEL OF AUTOMATION
Inventory
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Design Alternative 2 - This alternative would automate two
o"f the more basic activities in the UIC Program; that is,
permit application tracking and maintenance of the UIC
operations inventory. These activities are among the most
demanding in terms of manual processing. The simplicity of
these systems suggests a distributed management system
utilizing conventional files. The management reporting
would be batch oriented with necessary summary and program
reporting performed manually.
Design Alternative 3 - In this alternative, in addition to
the automation provided under Alternative 2, the screening
and maintenance of the self-monitoring reports would be
automated. In addition, optional automated tracking of
inspection schedules and a special reporting capability
would be supported to assist in reporting and basic program
analysi s.
Design Alternative 4 - In addition to the automation of the
capabilities provided in Alternative 3, Alternative A adds
the capability to support Enforcement in action tracking,
and program management in detailed analyses of program
effectiveness. This concept would require a relatively
complex system and represents the limits of what should be
automated for the UIC program.
Numerous other alternatives could be considered for automating, or not
automating, various subcomponents of these activities; however, we
believe that the alternatives presented represent the basic decisions
which EPA should make in proceeding with the general design. As the
regulations are clarified, the specifics with regard to the details
of the design can be developed within this framework.
The other decision is how the system should be implemented with
regard to the administering organizations. Clearly, to support the
EPA Regions in managing designated States for which EPA retains
administrative authority, a centralized system must be supported on
an EPA computer, either the Washington Computer Center (WCC) or the
National Computer Center (NCC). For those States taking primacy, the
situation is considerably more complicated. The options for a primacy
State are as follows:
The State could use a centralized EPA system through one of
the EPA data centers
The State could support the UIC program providing a manual
interface to the Federal Reporting System
The State could utilize its own automated system with an
automated interface to the Federal Reporting System
1-8
-------
The State could use a version of a standard UIC Information
System supported by EPA, but operated on a State facility.
Since EPA must develop a computerized system to support its own
requirements, the decision for EPA is whether it should also provide
the implementation and operational support for a distributed mode of
operation in the States. That is, whether EPA should build a version
of the UIC Information System which is transferrable to the states
for operation on their own equipment. States which desire to utilize
a centralized EPA system would have the access to that system
regardless of whether or not the distributed capabilities are supported
by EPA. This decision does not impact the fact that interfaces will
have to be designed with a Federal Reporting System for manual entry
of data, entry from a standardized EPA system, and from the custom UIC
systems currently operational in several States.
4. COST EFFECTIVENESS ANALYSIS
In order to determine which of the alternatives and implementation
strategies are most appropriate for implementation by EPA, we have
analyzed each in terms of both the costs attributable to the systems
and the impact on EPA's management and operation of the Underground
Injection Control Program. In Chapter IV of this report, we present
our detailed analysis of the costs of these alternatives over a five
year horizon and evaluate the impact of these alternatives in some
detail. In this section we present a brief overview of this analysis
in order to provide an understanding of our recommendations.
(1) Cost Methodology and Assumptions
The cost estimates presented include both the direct out-
of-pocket expenditures by EPA and opportunity costs incurred by
EPA. The estimated out-of-pocket costs include such items as:
expenditures on contractors for design, development, and
implementation; computer resources supplied by MIDSD; and
contractor data entry. These items would be directly budgeted
items for the program. In addition, we have estimated the
opportunity costs to EPA for the Underground Injection Control
Information System. These costs primarily include the personnel
required by headquarters and the Regions to support the system
processes. These are opportunity costs in the sense of
opportunity lost. That is, although EPA may not hire additional
personnel for support of the system processes, the commitment of
these personnel represents a loss of these capabilities for
performance of other EPA functions. Our analysis of the state-
level operations utilized the same methodology for costing as
for the EPA Regions, with adjustment for the impact of distributed
operation. Full costs were developed in each case; however, the
analysis did not consider to whom the cost would be attributable.
Because of the complexity of the decisions which face ODW
in analyzing its alternatives for the Underground Injection
1-9
-------
Control Information System, we have presented the costing in two
steps, oriented to the specific decisions. That is, we first make
the decision as to what level of automation should be developed
by EPA. This is presented in terms of the design and development
of a system for EPA's own needs in administering State programs
through the Regions. Given the level of automation appropriate
to EPA, we then proceed with the decision as to whether EPA should
invest the additional funds in developing a distributed system
to support the States who would prefer this approach. More
detailed decisions, such as whether to proceed with a data base
management system, are deferred to the general design process
where sufficient detail can be developed with regard to the data
element content and structures.
(2) The Level of Automation Decision
In developing the cost to support the first decision, that
is the appropriate level of automation, we have developed the
following cost estimates for each alternative:
The costs for the design and development of the Underground
Injection Control Information System from detailed design
through systems test.
The cost to EPA Headquarters for the prototype
implementation and operational maintenance of the system.
The additional implementation and operational costs for a
typical small State administered by a Region (where small
is defined as a State containing approximately 1,000 active
UIC operations).
The additional implementation and operations cost for a
large State supported by an EPA Region (where large is
defined as approximately 35,000 UIC operations).
The first two of these costs is basically the fixed cost that
would be incurred for the design and operation of a UIC
Information System, where the latter two are incremental costs
for the implementation and operation of each State within a
Region. These costs are presented in Exhibits 1-4 and 1-5 for
both the base estimates and the full life cycle costs.
In order to decide on an alternative both the fixed and
incremental costs have to be considered. Presented in Exhibit
1-6 is a graphic display of the estimated life cycle costs for
implementation and operation of an Administrative Agency (State)
as a function of its number of UIC operations. The costs do not
include EPA's fixed costs, they are the incremental costs per
State. The projections are based on the two cost estimates, large
and small, for each of the alternatives. This projection assumes
a linear relationship. For all alternatives the costs, as
1-10
-------
EPA HEADQUARTERS LIFE CYCLE COSJ SUMMARY
(DOLLARS IN THOUSANDS)
ALTERNATIVE 1
ALTEnNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 4
Qui
ul Pocket
0 |ipur-
tmiity
Total
Out
uf Pocket
0|ipt)f-
limily
Total
Out
uf Pocket
(unity
Total
Out
uf Pnckcl
0|i|iin
liinity
Total
Desiuii &
Development
40.5
5.5
54.0
153.2
31.6
104.8
274.6
40.4
323.0'
302.0
73. 2
456.0
liii|ilciiiL'iilatiiiii
-
-
-
9.0
2.0
12.6
16.7
5.6
22. 3
17.7
6. 3
24.0
0|iuialiuu
.6
3.3
3.9
110.2
121.6
2 39.0
163.6
121.6
205. 2
195.0
139. 0
3 34 .0
l.ifc Cycle
49. 1
8.0
57.9
281.2
156.0
4 37. 2
4 54.9
175.6
630. 5
595. 5
219. 3
014 .0
m
X
X
E
h
-------
ADMINISTRATIVE AGENCY
LIFE CYCLE IMPLEMENTATION & OPERATIONS
COST SUMMARY
(DOI.LARS IN THOUSANDS)
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 1
Out
of Pocket
Oppor-
tunity
Total
Out
nl Pockcl
Oppor-
tunity
Total
Out
nl Pocket
Oppor-
tunity
Total
Oot
ol Pocket
Oppor-
tunity
To Inl
SMALL
ADMINISTRATIVE AGENCY
Implementation
0.7
23.2
31.9
.25.8
4.6
30.4
33.3
7.7
41.0
36. 3
8.1
44.4
(l|ieiatimi
8.4
195.7
204.1
81. 3
150. 2
231.5
132.6
139.1
271.7
145.4
149. 2
294.6
Lite Cycle
17.1
210.9
236.0
107.1
154.0
261.9
165.9
146.8
321.7
101.7
157. 3
339.0
LARGE
ADMINISTRATIVE AGENCY
Implementation
15.0
319.0
334.0
447.9
12.4
460. 3
454.9
16.8
471.7
4 50.0
17.4
475.4
Upcialioii
20.9
1600.0
1716.9
165. 3
1504.6
1669.9
392.5
664. 3
1056 , 0
4 59.9
665.2
1125.1
Lilo Cycle
4 3.9
2007.0
2050.9
613. 2
1517.0
2130.2
04 7.4
601.1
1520.5
917. 9
602.6
16O0.5
-------
IMPLEMENTATION AND OPERATION COSTS AS A FUNCTION OF NUMBER OF INJECTION
WELLS FOR AN ADMINISTRATIVE AGENCY
LIFE CYCLE COSTS
2.130
2,050
(DOLLARS IN THOUSANDS)
2,000
1,700
1,600
1,528
1.600
1,400
1,200
1,000
800
600
400
339
312
262 '
218
200
35.000
1,000
NUMBER OF INJECTION WELLS m
X
x
CD
-------
expected, increase with the number of operations; however, not at
the same rate. In fact most of the automated alternatives rapidly
overcome the lower implementation costs for the manual approach.
This is an over-simplification of the costs and cost
relationships. We would not expect linear relationships, but
rather that the automated options would exhibit some concavity
due to economies of scale in the automation. However, the chart
does illustrate that the more advanced automated alternatives
overtake the manual and minimal automation alternatives as soon
as the number of injection wells move up around 6,000.
It is important to point out that the cost analysis, and
this illustration address the selection of one of the alternative
system concepts/ not the determination as to which state or region
should automate. There are considerable cost estimation errors
in any initial feasibility study. These estimates for a UIC
system can and should be extended once the general and detailed
designs have been completed. At that time the estimates should
have a reliability which would offer the potential for making
decisions as to system implementation for a specific state or
reg ion.
Exhibit 1-7 presents these costs from another perspective.
This exhibit displays the full life cycle costs, including EPA's
fixed costs for design through operation, for a large
Administrative Agency (State). This basically presents the costs
to EPA if only one State were implemented. The lowest cost is
for the manual approach, which indicates that development of an
independent UIC Information System would not be justified for an
individual State. However, implementation of Alternative III by
EPA can almost be cost justified for one large State
implementation. Assuming more than one such State will utilize
the system, the cost savings are potentially significant.
Based upon these estimates, we believe that, if EPA is to
administer at least one large State, the additional cost for
implementation, design, and development of Alternative III over
Alternative I is justified in terms of life cycle cost. This
primarily reflects the substantial decrease in operating cost
due to the automated screening and maintenance of self-monitoring
reports in Alternative III. Alternative IV provides the same
capability but is always more costly than Alternative III.
Alternative IV also provides management analysis and support
capability; however, this added complexity does not appear
justified in the near term.
On the assumption that more than one large State, or Region
with a large State, will utilize the UIC Information System, we
recommended implementation of Alternative III. This is based upon:
1-11
-------
LIFE CYCLE COST PROJECTIONS
(DOLLARS IN THOUSANDS)
LARGE STATE
Cosl
COMl|)OIIL>ltll
ALTERNATIVE 1
ALTEI1NATIVE 2
ALTERNATIVE 3
ALTEI1NAIIVE 1
Oul ol Pockel
E«|ietuoi
Dpj> oitu nily
Coiti
Tolal
OulolPockel
Expenses
U|i|ioi1unily
Coils
Tolnl
OulolPockel
t x |ieiises
CiisIj
ToUl
Out ol Puckel
Expenses
0)i|MiiUinity
Cnsls
Total
Syiltm Doilgri & D«ralopm«ii9
in
CO
i
5.5
54.0
153.2
31 .6
1R4 R
274.6
48.4
323.0
382.8
73.2
456.0
EPA HimIiiuiiUii ImpUmanlallot
¦nd Optiallont
.6
3.3
3.9
128.0
124.4
252.4
180.3
127.2
307.5
212.7
146.1
358. fi
AtfmiilitrsfHin Ag*i«cy
Iniptimciilitloii ¦ltd Opmlloni
43.9
2007.0
2050.9
613.2
1517.0
2130.2
847.4
681.1
1528.5
917.9
682.6
1600.5
LIFE CYCLE
93.0
2015.8
2108.8
894.4
1673.0
2567.4
1302.3
856.7
2159.0
1513.4
901.9
2415.3
-------
Alternative III offers the lowest implementation and
operation cost to an Administrative Agency for all but the
smallest agencies.
Implementation in only one large Administrative Agency
almost cost justifies EPA's fixed costs.
Alternative III minimizes the manual reporting burden on
the Administrative Agency.
The added complexity of Alternative IV does not meet the
evaluation criteria for minimizing required levels of
technical support. It provides additional capability at
added cost. These enhancements can be added later, when the
Program has matured and there is greater certainty of the
need.
Alternative III provides significantly more management
reporting and analysis capability than Alternative II, as
well as a cost advantage.
In summary, Alternative III offers significant advantages to EPA
both in terms of cost and effectiveness.
(3) The Implementation Strategy Decision
Once a decision was made with regard to recommendation of
Alternative III, we proceeded with the analysis of which
implementation strategy would be most appropriate for EPA. To
accomplish this we estimated each of the above cost components
for the case in which EPA would design, develop, implement, and
support the system on a distributed basis. This would require
EPA to implement and support operation of both the centralized
system and distributed State systems.
In the costing of the distributed systems, costs were
included for the additional development costs for the portability
of the distributed system, additional training for the State
programs, and additional system maintenance cost in both EPA and
the States. We decreased some cost items, such as the
telecommunications costs, which would not be incurred by a State
utilizing the distributed system.
In order to provide EPA with some basis for the magnitude
of the cost impact for the centralized vs. distributed approach,
while considering all of the various options the States would
have in terms of primacy, we developed a series of three scenarios
for the UIC program. These considered several different
possibilities for the program in terms of the decisions of the
designated States who accept primacy. These scenarios ranged
from an assumption that many of the States would proceed with
their own systems, to the potential that many of the States would
1-12
-------
participate with EPA in the UIC Information System. These
scenarios are presented in Exhibit 1-8. The cost impacts of these
scenarios versus the centralized/distributed decision are
presented in Exhibit 1-9.
Clearly, in each case the distributed strategy incurs
significant additional costs. These additional costs must be
weighed against the benefits that may be provided by a distributed
system. The analysis considered the following:
The distributed approach incurs significant additional costs
for operations and system maintenance because each version
of the system must be maintained separately.
The distributed approach may encourage more States to
utilize the UIC Information System, reflecting
confidentiality concerns in a centralized approach.
The centralized approach facilitates further system
enhancement and relieves the State of local operational
burdens.
The distributed approach offers the State additional
flexibility for customizing; however, at the substantial
risk of major system maintenance costs.
The estimation of the probability of which scenarios might
occur and the impact of the system on State decisions versus
other program considerations is well beyond the scope of the
study. However, because of the limited number of States believed
to be influenced by this decision, we believe that the additional
cost of the distributed approach would not be justified for the
UIC Program. As a result, we have recommended the centralized
approach for the development of an initial system. To the extent
possible, the systems design should be developed in a manner which
encourages States to participate with EPA on a centralized basis.
This would include prime consideration in the design of the UIC
Information System of the protection of the confidentiality of
the State's data while on a system operated by EPA.
5. RECOMMENDATIONS
In summary, as a result of our cost effectiveness analysis, we
have concluded with the following recommendations:
EPA should implement the conceptual design presented in
Alternative III
EPA should proceed with the development of a centralized
system, while emphasizing support for State concerns in the
design.
1-13
-------
SCENARIOS FOR CENTRAL VS DISTRIBUTED
ALTERNATIVE IMPLEMENTATIONS
Scenario
State
CENTRALIZATION ALTERNATIVE
Primacy State
Own System
EPA Central System
Non-Primacy
State
1
Small
6
4
1
Large
5
1
2
2
Small
4
5
2
Large
4
2
1
3
Small
1
7
3
Large
5
1
1
Scenario
State
DISTRIBUTED ALTERNATIVE
Primacy State
Central
Ouvn System EPA System
Distributed
EPA System
Non-Primacy
State
1
Small
6
2
2
1
Large
5
1
1
2
Small
4
3
2
1
Large
4
1
1
1
3
Small
1
4
3
3
Large
5
-
1
1
-------
ALTERNATIVE SCENARIOS LIFE CYCLE COST PROJECTIONS
(DOLLARS IN THOUSANDS)
CENTRAL
DISTRIBUTED
Alternative
Cost
Out of-Pocliut
0 |i|i tn t ii n i 1 y
Aimiml
Outui-Pncliel
Opportiinity
Annual
Sccnariii
Components
E K |10IISUS
Costs
Total
Expenses
Cos Is
Total
System Dosign & Development
274 .6
cc
323.0
326.6
5U. 1
304 . 7
1
EPA Headquarters Implementation
and Operations
100. 3
127.2
307.5
212.9
15.1. 2
364. 1
Administrative Agency
Implementation and Operations
2524.3
2096.2
4620.5
2006.6
2560.1
5446.7
LIFE CYCLE
2979.2
2271.0
5251.0
34 26. 1.
2769.4
6195.5
Systum Dusign & Development
274.6
j
CD
P
323.0
326.6
50.1
304 . 7
2
EPA tlu«iil<|uartors Implementation
and Operations
100. 3
127.2
307. 5
212.9
151.2
164 . 1
Administrative Agency
Implementation and Operations
3,703.5
3,070.9
6,774.4
4,06 5.0
3,534.0
7,1.00.6
LIFE CYCLE
4,.150.4
3,246.5
7,404.9
46()5. 3
3/44..I
H 14'l. 4
System Design & Development
2 74.6
40. 4
3 2 3.0
3 21). (>
50.1
304 . 7
3
EPA 1 |uud<|(iarters Implementation
and Oporations
1 00. 3
1 27.2
307.5
2 1 2 . 9
151. 2
31.4 . 1
Administrative Agency
Implementations and Operations
3353.0
20 30.2
6J04.0
300 1 .')
34 51.0
7 2 52.9
LIFE CYCLE
3000.. 7
3005.0
60L4.5
4 34.1 .4
361.0. 3
01)0.1 . 7
x
i
-------
These recommendations would provide the EPA Regions, and any State
which desires to participate, with the automated capability for permit
application tracking and maintenance, maintenance of a UIC operations
inventory, the tracking of inspection schedules, screening and
maintenance of self-monitoring reports, and a basic report analysis
and inquiry capability. The enforcement action tracking and more
sophisticated program analysis capability would be left for system
enhancements and the resolution of the regulations.
The time schedule for the implementation of this recommendation
is presented in Exhibit 1-10. As shown, the milestones beginning with
the general design through implementation are coordinated with the
anticipated date for the promulgation of the regulations. In addition
to the recommendations above the implementation approach presents some
additional recommendations. These include the following:
The specific requirements of the Federal Reporting System
to support the monitoring role of EPA Headquarters and
Regions should be defined as soon as practicable. A
preliminary concept for these requirements is presented in
Chapter V.
We recommend that the system should first be implemented
only for the oil and gas area of the Underground Injection
Control Program, and that the other types of
operations/injection wells be added to the data base on a
phased basis.
Before general release of the UIC Information System, the
system should be thoroughly prototype tested in a small
State for which EPA is the administering authority.
The implementation of the system, even if centralized, should
be kept simple until EPA and the States have resolved the
initial issues normal in any emerging program.
The other design decisions, such as whether a DBMS should be utilized
in the centralized system, whether the system should be installed on
WCC or NCC, and the details of the system design are left for the
analyses in the general systems design process.
In summary, we recommend that the Office of Drinking Water proceed
with the general design of a Underground Injection Control Information
System. This system would provide the automation of many of the basic
files for maintaining the UIC inventory, permitting, and compliance
monitoring while avoiding the more sophisticated applications required
in other activities of the program. To the extent practicable the
centralized design should be made as attractive as possible to the
States to encourage their utilization of the system on a centralized
basis.
1-14
-------
UIC MANAGEMENT INFORMATION SYSTEM
IMPLEMENTATION PLAN
MAJOR STEPS
1978
Jun Jul Aug Sep Oct Nov Dec
1G79
Jan
Fell
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Jail
1980
4r
Oct
SYSTEM DESIGN AND DEVELOPMENT
¦ General Design
¦ Detailed Design
Program Specifications, Code and Test
Support Procedures Development
REGIONAL PILOT IMPLEMENTATION
Training
i Data Conversion
Prototype Operation
Implementation Evaluation
FULL IMPLEMENTATION START UP
p
m
X
I
03
-------
REQUIREMENTS ANALYSIS
-------
II. REQUIREMENTS ANALYSIS
The Office of Drinking Water (ODW) of the U.S. Environmental
Protection Agency is currently in the process of finalizing regulations
for implementation of a State Underground Injection Control (UIC)
program. These regulations will establish minimum requirements for
effective State programs to prevent underground injection practices
which endanger underground sources of drinking water. The regulations
are being prepared in accordance with Subtitle C of the Safe Drinking
Water Act of 1974.
ODW is in the process of assessing the feasibility of developing
a data management system to meet State requirements for management of
the UIC program, and to support its role as a program monitor. The
information requirements necessary for effective management and
monitoring of the UIC program are presented in this chapter. The
requirements analysis is presented in four sections:
Background - describes the practice of underground injection
and briefly discusses the legislative history of events
leading to the requirement for a UIC program; identifies
the objectives and activities of such a program, and
describes the current environment.
Information Requirements - identifies the three levels of
UIC program management, their structure, and information
requirements.
Issues - presents issues which affect UIC program data
management.
Evaluation Criteria - presents the criteria that will be
used to evaluate the alternative system concepts. These
include both user (effectiveness) and design (efficiency)
oriented criteria.
1. BACKGROUND
Today the drinking water for over 100 million Americans comes
from underground sources. These sources, commonly referred to as
groundwater, are found in geological formations known as aquifers.
Aquifers contain enough saturated permeable material to surrender
significant quantities of groundwater to wells or springs.
Historically groundwater has been relatively free of contaminants that
would create pollution and effectively eliminate it as a source of
drinking water. A recent increase in the practice of subsurface
emplacement of fluids by various industries has led to the growing
possibility of groundwater contamination.
II-l
-------
(1) Types of Underground Injection
Far and away the largest number of operations which employ
subsurface emplacement of fluids are related to the production
of oil and gas. These operations include:
Enhanced recovery wells which are used to inject fluids for
the purpose of stimulating production of oil or natural gas
Brine disposal wells which are used to dispose of salt water
or other fluids which are brought to the surface during oil
or gas production.
There are other types of operations which require the subsurface
emplacement of fluids. Although these operations are not nearly
as numerous as those related to oil and gas production, they do
include some of the most contaminating substances injected. These
operations include:
Hydrocarbon storage wells which are used to inject
hydrocarbons into an underground foundation for storage
purposes; or which are used for injection of fluids for the
purpose of recovery of stored hydrocarbons
Industrial disposal wells which are used for injecting
industrial wastes
Municipal disposal wells which are used for the injection
of effluent from a municipal collection, storage or treatment
facility
Solution mining wells which are used to inject a fluid
containing leaching chemicals for the purpose of recovering
metals such as copper and uranium; or to inject water or
other fluids for dissolving, for subsequent recovery,
minerals such as sodium chloride, potash and phosphate
In situ gassification wells which are used for the injection
of air and fuels to gassify fossil fuels such as coal, tar
sands and oil shale
Drainage wells which are used for injection of urban,
agricultural or highway runoff and excess ponded surface
waters.
In addition to these several other types of wells are used for
subsurface emplacement. These include nuclear waste disposal or
storage wells, domestic septic system wells, recharge wells, air
conditioning return flow wells, cooling water return flow wells,
salt water intrusion barrier wells and subsidence control wells.
11-2
-------
One additional operation which can result in the subsurface
emplacement of fluids, and thus pose a potential groundwater
contamination hazard, is surface impoundments. Surface
impoundments consist of pits, ponds, or lagoons which are used
for storage or disposal of wastes. The contamination threat from
surface impoundments is caused by the potential for seepage into
the ground of the contents of the pit, pond, or lagoon.
(2) Legislation and Implementation
In 1974, Congress enacted the Safe Drinking Water Act. This
Act amended the Public Health Service Act "to assure that the
public is provided with safe drinking water." Two mechanisms
have been established to meet this goal:
Establishment of minimum Federal Standards that all public
water systems must meet
Development of a program to protect underground drinking
water sources via a Federal/State cooperative effort based
on the predetermined standards and regulations administered
by the States. This program shall:
prohibit any underground injection not authorized by
State issued permits or rules;
ensure that permit or rule applicants satisfy minimum
standards;
include inspection, monitoring, record keeping and
reporting requirements;
apply to all practitioners of underground injections,
including Federal agencies;
not interfere with or impede oil and gas underground
injection and related activities as long as they do
not endanger underground sources of drinking water.
Regulations are currently under development to support the
underground injection control program. These regulations have
been drafted and are currently under going internal review at
EPA. They are scheduled to be proposed by June, at which time
there will be a sixty (60} day period of comments by affected
parties. At the end of the 60-day comment period, EPA will have
another 60 days to review and respond to the comments received.
After this second 60 day period, the regulations will be published
in the Federal Register as final. The regulations will become
effective 270 days after publication in final form.
The implementation of the national program to control the
practice of underground injection of these fluids will utilize
11-3
-------
a phased approach. The objective of this approach is to allow
for a manageable program implementation process. While the
ultimate goal is to include all 56 States and territories in the
program, the initial phase is limited to those States in which
there is known, significant practice of underground injection.
The Administrator will designate the States which are to be
included. A State will be a candidate for designation if, in the
judgement of the Administrator, "a State underground injection
control program may be necessary to assure that underground
injection will not endanger drinking water sources."
A designated State which desires primary enforcement
responsibility (primacy) is required to provide proof by means
of an application to the Administrator. The application must
show that the State has adopted and will implement a UIC program
which satisfies the requirements of EPA regulations, and will
maintain records and submit reports in conjunction with its UIC
program activities as may be required by regulation. When the
application is approved by the Administrator, the State is
assigned primacy for its underground injection control programs;
otherwise, the corresponding Region will retain primacy.
{3) Program Participants and Responsibilities
The UIC program is designed to monitor underground injection
practices which have the potential to contaminate water, and to
report the information to three levels of program management.
These three levels consist of EPA Headquarters, EPA Regional
Offices, and the individual States. Each level has responsibility
for several aspects of the program.
National Level
At the national level, EPA Headquarters has the
responsibility of overall program management. This
responsibility includes designating States which require
underground injection control programs, obtaining an initial
inventory of underground injection facilities in designated
States, and monitoring program status on a nationwide basis
through annual reports. The primary responsibility for
designated States to be included in the program lies with
the Administrator. His decision is based on information
supplied by both Headquarters and Regional personnel,
regarding the danger to underground drinking water sources.
Proposed regulations also provide grants for States to
assist in funding of UIC or underground water source
protection programs. Primacy would serve as a basis for
allocation of grant funds in the first year. Non-designated
States could also apply for funds if they can demonstrate
the need for a UIC program. In the first year, proposed
allocations would be made to States on the basis of
11-4
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population, geographic area, and quantity of ground water
used for drinking water. In subsequent years, allocation
would be made on the basis of the number of underground
injection facilities within a State as well.
The requirement for obtaining a national inventory of
injection wells, therefore, is multi-fold. A primary purpose
of this inventory will be in support of the allocation of
available grant funds to States with primacy. In addition,
the availability of a national inventory allows Headquarters
to respond to inquiries concerning number of facilities,
location of facilities, types of facilities, and other
facility inventory related information. These inquiries
will be forthcoming from Congress, special interest groups
and perhaps other Federal agencies. Finally, the inventory
will provide a source of data for analysis of nationwide
trends and conditions useful in long-range planning.
The ability to effectively monitor the UIC program at the
national level depends on the program information received
by Headquarters. The regulations require that each State
that has primacy must submit an annual report to EPA. The
ultimate recipient of all the annual reports is EPA
Headquarters. The information required on the annual report
includes a summary of violations and enforcement actions
taken, an updated account of inventory additions and
deletions, and other information as required by regulation.
Through this information Headquarters can identify possible
areas of priority during the upcoming program year. These
areas of priority may include:
Specific geographic areas where an overwhelming number
of violations have occurred
Specific types of operations which are more in
violation than others
Areas where new types of injection operations are
emerging.
The areas of priority effectively dictate the oversight
direction that Headquarters will take in the upcoming year.
This direction is then relayed to the EPA Regions and the
authorized States.
Regional Level
The Regional office can have a dual role in the program. A
designated State may accept or reject primary enforcement
responsibility (primacy) for the Underground Injection
Control program. When the State accepts primacy, the
Regional EPA office acts as a program monitor and assists
II-5
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the State's efforts as required. However, should a State
reject primacy, the Regional EPA office would assume the
additional role of program administrator.
As program monitor, the Regional EPA office:
Reviews and acts on State requests for primacy
determination
Monitors regional program status through required
periodic reports
Provides technical assistance to States upon request
Maintains a current regional inventory of underground
injection wells.
As program administrator, the activities of the regional EPA
office would duplicate the activities of the primacy State
described in the next section. In the program monitoring
role, the Regional Administrator (RA) is considered an agent
of the Administrator and as such performs many functions
which the law and regulations require of the Administrator.
Among these functions the RA and appropriate regional staff
review States' requests for primary enforcement
responsibility and approves or denies the requests. The RA
will also supply information to the Administrator to support
the State designation process.
In its role as program monitor the Region will require
periodic reports from authorized states. These reports will
provide a summary of violations, enforcement actions,
inventory additions and deletions, and other information as
required by regulation. The information from these reports
will permit the Region to effectively monitor the UIC
programs within its jurisdiction. The information will also
allow the Region to respond to inquiries from affected
parties, interest groups and the general public.
A national inventory of injection wells would be, in reality,
the sum of the Regional inventories. The Regions would
develop the actual inventory information. As the Region
obtains inventory information from its States and updates
its existing inventory, it would, in effect, update the
national inventory. The regional inventory would be used
primarily as a control list of underground injection
facilities. The data in the inventory could be manipulated
to perform trend analyses by State, by type of injection
activity, and other inventory data elements. The inventory
would also support the Region's responsibility to respond
to inquiries concerning the UIC community size and
d istr ibution.
II-6
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State Level
Primacy States act as program administrators. In this role,
the State issues permits for underground injection
operations, monitors operations through the use of operator
self-monitoring reports and on-site inspections, maintains
a current inventory of State underground injection wells,
and minimizes violations through monitoring and enforcement
actions. The State is also responsible for periodic
reporting on program status to the Regional EPA office. This
role will be discussed in detail below, since it is in support
of this role that the proposed system is focused.
A State which has not taken primacy would have its Federal
underground injection control program administered by the
EPA Region in which it resides. The non-primacy State is
under no formal obligation to provide the administering
Region with information required by the regulations.
Operator's would submit reports directly to the EPA regions,
and inspections and enforcement actions would be performed
by the Region.
{4) Current State Environment
As previously indicated, there is a wide variety of wells
which may pose a danger to underground drinking water sources.
These include oil and gas production shallow disposal well
operations, hydrocarbon storage wells, industrial and municipal
disposal wells, solution mining wells, nuclear waste disposal and
storage wells, in situ gassification wells and drainage wells.
This broad array includes different types of industries which
may be regulated at the State level, not by a discrete UIC program,
but by a variety of health and environmental protection programs
and organizations within the State government. These
organizations may all reside within a single State agency, or
they may encompass a number of State agencies. Thus, there are
two kinds of State administered programs:
Programs administered by a single State agency
Programs administered by multiple State agencies.
The separation of multiple agency responsibility (or multiple
organization responsibility within a single agency) usually
occurs between oil and gas production and other underground
injection activity. There are additional separations of functions
among health and conservation groups. The types of agencies which
are administering or will administer the UIC program in the
designated States include:
Commissions which regulate oil and gas production
II-7
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Department of Natural Resources
State Environmental Agency
State Department of Health
State Water Resource Agencies
State Departments of Conservation.
Many of these agencies currently administer programs to control
underground injection activities. These programs are regulated
by State enacted legislation. In some instances, State
legislation and regulations are more stringent than the Federal
regulations which have been developed.
The EPA position with regard to State programs regulating
underground injection practices is not to supplant the State
regulations, but simply to ensure that the State program is
effective. Indeed, the Agency will guide and encourage adoption
of State UIC programs, to include providing grants and data
management tools to assist the State programs. The UIC program
is viewed as a cooperative effort between EPA and the States. An
initial set of Federal regulations was submitted to the States
for review. The regulations were subsequently modified to reflect
State comments and will soon be distributed for another review.
This kind of interaction between the States and EPA is essential
for the implementation of an effective UIC program.
2. INFORMATION REQUIREMENTS
The activities at the three levels of UIC program management
described previously require different levels of information to
support them. In this section we present the kinds of information
required at the State, Regional and National levels. The information
is described in terms of program administration needs and program
monitoring needs. Therefore we present the information requirements
of:
Administering State or Region
Monitoring Region
National Headquarters.
Exhibit II-l contains an overview of the information requirements for
each of these levels of program management.
(1) Administering State or Region
The objective of the administering agency or organization
is to effectively manage the UIC program for which it is
II-8
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OELGATEO
STATES
/
ADMINISTERING
REGIONS
UNDERGROUND INJECTION CONTROL PROGRAM
INFORMATION REQUIREMENTS OVERVIEW
EPA REGION - PROGRAM MONITOR
V EN TORY IM FORMATION
Acliwu Operation
Ownership
Location
Operation Classification
Nmiilwi of Wells, Holes, ulc.
Permit Number
Permit Slalus
I'unnil Criteria
. . Pressures
. . Volumes
. . Amounts
. . tilC
Inactive Operation
Archival Information
. . Ownership
. . Classification
. . Location
.. Number of Wells. llolos. etc.
. . Slaius
-- Inspection Finding
. . I'luuued
. . Abandoned
. . Peimil/Affidavil Number
Siinimaiy Inlonnaiion
Actives. Inactive*
Operation Classification
INITIAL
! NVENTORY INF OHM ATI ON
Stale by Slato
Acliwu Operations
. . Ownership
. . Location
. . Status
Inactive Operations
. . Ownership
. . Location
. . Stains
Regional Summary
Actives, Inactive*
Operation Classification
ANNUAL
A
rs
INITIAL
f
EPA NATIONAL IIEAOOUAIITEIIS
nMJ9!^L!Nventory
Region by Region
Active Operations
Inactive Operations
National Totals
Active
. . Classification
. . Status
Inactive
. . Pluuijed
. . Abandoned
. . Shutdown
Regional Inventory Adjustments
New Operations
. . Ownership. Location. Classification
Shutdown Operations
. . Ownership. Location. Classification
Abandoned Operations
. . Ownership. Location. Classification
GQM!!L!fLN£E information
e Permit Inlormatiun
Ownership & Lacmititi
Permit Number
Permit Status
Purmil Criteria
. . Pressures
. . Volumus
Compliance Schedule
Scheduled Inspections
Inspection Findinu*
Violations
- Type & Seventy
Oate ol Violation
Locution of Violation
ENrO!"!C-EMtNT ACTIONS
Violation Type & Seventy
Enforcement Action
Action Type
Action Dato
Action Status
Action Ilistoiy
PERIODIC
V
COMPLIANCE SUMMARY
Stale by Statu
Violation Totals
- Typo
. . Severity
. . Date
Inspection Totals
. . Scheduled
. . Conducted
. . Violation Detected
. . Inspection Follow-up
ENFORCEMENT SUMMARY
State by Sialu
Enforcement Actions
. . Violation
. . Aclloil Type
. . Action Slalus
REGIONAL SUMMARY
Number of Incidents of
Non-Compliance
Number of Enforcement Actions
I ol.il liiventdiy Adjustments
ANNUAL
ANNUAL REPORT
Inventory Adjustments Summary
New Operations
Shutdown Operations
. . PJu(JU"d
. . Permit Revoked
. . etc.
Abandoned Opuralions
Violations Siunmaiy
National
Regional
Slates
Enforcement Actions Siunmaiy
National
Regional
States
llouiiljlionv Sulipail F
I'luyr
Dniiusal. Recliaiye Wells
X
I
-------
responsible. This objective is accomplished through such
activities as:
Granting permits
Compliance monitoring via site inspection and self
monitoring report screening
Compiling and maintaining an inventory of underground
injection operations
Minimizing violations through effective enforcement action.
These activities require certain items of information that will
enable them to be carried out successfully and provide for
effective program administration. These information requirements
are basically the same, regardless of whether it is a single
agency environment or a multiple agency environment, or an
administering region.
Exhibit II-2 depicts the activities associated with
administering the CJIC program, and the information required to
carry out the activities.
Granting Permits
This activity consists of reviewing permit applications
submitted by underground injection operators, issuing a
permit to the operator and maintaining a file of active
Permittees. The information required to support this
activity comes from the permit application. This application
provides the following information:
Operator identification.and location
Operation description including engineering,
geological and hydrological information
Equipment and techniques for operation monitoring and
contingency plans in case of failure of underground
system.
With this information the program administrator can make a
decision to issue or deny a permit. With the issuance of a
permit the Permittee file is created. This file contains
required permit application data, the assigned permit number,
and permit conditions and schedules.
Compliance Monitoring
This activity consists of screening operator self-monitoring
reports, scheduling and conducting site inspections,
II-9
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UNDERGROUND INJECTION CONTROL PROGRAM
INFORMATION REQUIREMENTS AND PROCESSING FLOW
ADMINISTERING STATE OR REGION
nECIPIENT
Pei
mit Application
Opera lex Identification
e
Location Oata
Addieu
- Longitude. Latitude
e
Engineering Oata
- Map
- Process
e
Operating Oata
- Volume*
Pressures
Monitoring Pi am
Contingency Plant
AbwdootJ/Hmtid
Wall Idantille*
Notification
P«imii Application
Allidavit
Operation
¦ - Statu*
Notification el
Ptoblim and
Coftective Action
Impectotl
Enlo'cament
Impaction Ropoil
Rcpvii Oale
Flndinfl
PlMUUItl
VohiiTMt
Amoonlt
Mechanical Intagiity
t«tl Ratirtl*
in*ento«y Itamt
Plugged/Abeiiduned
Well*
New Walh
EnlBiumtnl Action
Action Type
« Action Oata
Compl<«x*
Schadula
Sell Monitoring RapMt
e
Report Oata
Permit Criteria
Pressures
Volume*
- Amounts ITDSl
e
Reported Readings
- Praiiures
Volumes
Amounts 1TOSI
Neat Scheduled Date
Opetator ID Data
INVCNTOnv
a AdfuM Undarground
Intact kin Opwationt Inniiilwy
« P«mkl InlotnuticMi
. . N«w OpHilkxi
. . Ravocation
. . SuipMtion
. . Mod I Hoiat
PERMITTING
Rati** Petnilt Applkilioni
lisue 01 Oany Paimit
Summatiia and Tramler
Prtmil Oata to Allected
FUet
p«mittaa
Inventory
Compliance
COMPLIANCE MONITORING
SctMduti impaction
Conduct Impaction*
a Ra»lew Monitoaing Repotl*
Opetato* Sell Monitoiirtg
Impaction Findings
a Identify Violation*
lypa & Seventy
Notify OpaiitcM and Enlwct
CNFOnCEUEN T
Datatmina Requited Action
a Initijta Action
e Upan Action Fila
Action Oata
Action Typa
Statin
Foiluw-up Schedule
Update Allactad Filat
Permittee
Compliance
Violation*
reporting
e Pi«ji»e Periodic Program
Stalin flcpo«l
a Progtam Analysis Report*
INI EnN ALLY MAIN I AIMED OA I A
liifmilnty lnloi(TU\urri
No. ftvvokrrt
No. Applicalio
VioUlm.it
OullljrHliiio
Actiunad
Now
OiiqtMtm
rKiuti
Aitiliiium
D»trnaa,.*
UIC
Operator
Enforcement
Paitonnel
Program
Administration
X
I
-------
reviewing site inspection reports, identifying violations
and notifying both the operator and the enforcement
authority of a violation. The information which supports
this activity comes from the permit schedule and conditions,
the operator self-monitoring report and the inspection
report. Specific items of information include:
Compliance schedule
Permit conditions such as volume of fluids and
injection pressures
Inspection findings such as mechanical integrity test
results
Operator reported pressures and volumes for a reporting
per iod.
This information enables the program administrator to
determine whether or not an operator is in compliance with
the conditions of his permit and the existing regulations.
Compile and Maintain Inventory
This activity is required at the outset of the program and
is ongoing thereafter. The development of the initial
inventory consists of compiling active permits and recording
the operator identification, location and status
information. It also requires compiling archival
information concerning abandoned and plugged wells and
attempting to obtain as complete an inventory as possible
with the information available. The ongoing inventory
activity consists of periodically adjusting the existing
inventory. The information which supports this activity
comes from the Permittee file, plugged well permit
applications or notifications, inspection findings, and
historical well records. Specific items of information
include:
Status of inspection operation
Well operation identification and location
Identification of plugged or abandoned wells with
location information.
This information allows the program administrator to
maintain a current injection well inventory of all
facilities within the State.
Enforcement Action
11-10
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This activity consists of determining a course of action
based upon the type and severity of an identified violation.
It also involves initiating the specified action, scheduling
events, and tracking the action to completion. The
information which supports this activity includes compliance
screening, inspection reports, and the prescribed
enforcement response. The data includes:
Violation detected
Indicated action
Action date
Action status
Action timetable.
This information allows the program administrator to analyze
the effectiveness of enforcement actions and determine
priorities for enforcement activity.
(2) Monitoring Region
The role of the Region in the UIC program may be twofold.
For those designated States which do not choose to take primacy,
the Region becomes the program administrator. In the case of
those States which accept primacy the Region functions as the
program monitor. Exhibit II-3 depicts the activities and
supporting information requirements of a monitoring Region.
The objective of the monitoring region is to assure that
the administering State is in compliance with the Federal
regulations governing the UIC program. To accomplish this
objective the Region requires that the State periodically submit
program status reports. These reports contain the information
which the Region needs to analyze the effectiveness of the State
program. This information is in the form of summary data compiled
by the State. The information supports the activities of
inventory adjustment and overall program monitoring.
Inventory Adjustment
This activity consists of updating the Regional injection
well inventory with periodic input from the administering
States. The information required is on the program status
report and includes:
Additions in the form of new operations or restarted
operations
11-11
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EXHIBIT 11-3
UNDERGROUND INJECTION CONTROL PROGRAM
INFORMATION REQUIREMENTS AND PROCESSING FLOW
PROGRAM MONITORING REGION
SOURCE
DATA
ACTIVITIES
OUTPUT
RECIPIENT
Initial Inventory
UIC Operations
Ownership
Location
Permit Number
Administering
State or
Region
Program Status
Report
Inventory
Additions
Deletions
Permits
Issued
Oenied
Revoked
Compliance
Schedule Dates
Violations
Enforcement
Violations
Actions
Action date
Action status
INVENTORY
Obtain Initial Inventories
from Primacy States
UIC Population
. . Ownership
. . Location
. . Status
. . Permit Number
Update Inventory File
with Adjustment Data
Additions
. . New Operations
. . Restarted Operations
Deletions
. . Plugged Wells
. . Abandoned Wells
. . Shutdowns
PROGRAM STATUS
Review Permitting Process
Number Applications
Number Issuances
Number Denials
Number Revocations
Review Compliance Function
Number Inspections
Number Violations
Violations Severity
Review Enforcement Activity
Number of Actions
Type of Action
Action Status
Review Overall State Compliance
with Regulations
Permitting
Compliance
Enforcement
Reporting
REPORTING
Prepare Data for
National Annual Report
Inventory Adjustments
Violations Summary
Enforcement Actions
Summary
ANNUAL REPORT INPUT
Inventory Adjustments
Additions
Deletions
Violations Summary
Enforcement Actions
Summary
EPA
National
Headquarters
INTERNALLY MAINTAINED
Regional Inventories
Federal Regulations
State Regulations
-------
Deletions including plugged and abandoned wells.
Program Monitoring
This activity consists of a complete review and analysis of
the information provided in the periodic program status
report submitted by the States. The information analyzed
includes:
Number of permits issued, denied, or revoked
Summary of violations
Summary of enforcement activity.
This information enables the Region to identify areas where
States are not in compliance with the regulations and to
take steps to correct, to identify trends and set regional
priorities, and to measure the overall effectiveness of the
State programs.
(3) National Headquarters
The role of EPA National headquarters in the UIC program is
one of management authority and provider of information to
Congress and other Federal agencies, as well as to special
interest groups and the general public. Headquarters will
coordinate all information received from the Regions and States
which satisfy the Federal reporting requirement of the
regulations. Through analysis and report preparation,
Headquarters will perform its National oversight function and
inform the public. Analyses include assessment of regulations
effectiveness, national trends in underground injection
techniques, and effects of new inspection or other monitoring
techniques.
Exhibit II-4 shows the activities and supporting information
requirements of National Headquarters. The activities include
monitoring of the UIC program on a national basis and responding
to inquiries.
Program monitoring
This activity consists of correlating and analyzing the
annual report information provide by the Regions and States.
Information required to accomplish this activity includes:
Summary of violations
Summary of enforcement actions
11-12
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UNDERGROUND INJECTION CONTROL PROGRAM
INFORMATION REQUIREMENTS AND PROCESSING FLOW
EPA NATIONAL HEADQUARTERS
SOURCE DATA ACTIVITIES OUTPUT RECIPIENT
Regions
Information
Requestors
States
UIC Operators
Regional
Administrators
Federal Agencies
Congress
Environmental
Groups
General Public
Inventory
Regional
Summary
States
Summary
National
Annual Program
Status Report
Inventory Adjust-
ments
Violations
m Enforcement
Actions
UIC Program
Inquiries
Permits
Compliance
Enforcement
Status
ACTIVITIES
Review Initial Inventory
States
Regions
Total Nationwide
Correlate Regional
Annual Report Data
Inventory Adjustments
Violations
Enforcement Actions
Analyze Program Status
Permitting Procedures
Nature of Violations
Effect of Enforcement
Actions
UIC Population Trends
Prepare Annual Report
Respond to Inquiries
Determine Inquiry Validity
Research Inquiry Answer
Prepare Inquiry Response
2Z
Annual Report
Program Status
Regional
State
National
Inquiry Responsos
Program Status
Environmental
Projections
EPA
Office of Water
Supply
Office of
Enforcement
Administrator
Congress
Federal Agencies
Environmental
Groups
General Public
Regional UIC
Report
Region
State
Regions
INTERNALLY MAINTAINED DATA
Annual Report Archives
National Inventory
m
x
i
-------
Summary of permit activity
Inventory adjustments.
Respond to Inquiries
This activity consists of responding to inquiries from
various sources by determining the validity of the request,
researching the answer and preparing a response. The
information which supports this activity includes all
available detail and summary data which resides at the State,
Region or national level.
3. ISSUES AFFECTING UIC PROGRAM DATA MANAGEMENT
The objective of this study is to design a system concept to
manage the data in the UIC program. The system is directed toward
meeting the information requirements of the administering entities,
whether State or EPA Region. An analysis of the information
requirements defined and the complex operating environment leads to
the identification of issues which have an impact on the system concept.
Issues identified are:
Multiple agency administration
Jurisdiction of surface impoundments
Evolving regulatory environment.
Each of these issues is briefly discussed in the paragraphs which
follow.
(1) Multiple Agency Administration
This issue is one which affects those States which are
authorized to administer the program (primacy), and whose program
administration involves more than one State agency. EPA
regulations require periodic reporting of UIC information and
basic recordkeeping. The multi-agency structure complicates
compliance with the reporting requirements. Some aggregation of
data from the different agencies must be accomplished to produce
the required reports. This can be a complex, expensive effort if
data formats are different or levels of detail vary. Further,
responding to Federal queries, the State may also have to perform
an aggregation of data from different organizations. This
significantly affects State resources and the timeliness of the
response. For State operations, this multi-agency environment
may also result in less than effective control due to more complex
communication requirements and potentially incompatible data
bases.
11-13
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The simplest solution would be to locate the UIC program,
or possibly the responsibility for all UIC data, in one State
organization. However, this may not be feasible in many States.
As a result, much care must be exercised to develop procedures
which will assure effective control and permit sufficient
response to Federal regulations. At a minimum, EPA has encouraged
the States to designate a single point of contact for the Agency.
(2) Jurisdiction of Surface Impoundments
An issue which affects both EPA and the States is the role
of surface impoundments as it relates to the UIC program.
Originally pits, ponds, and lagoons which make up the surface
impoundments were believed to be under the jurisdiction of the
UIC program. However, there are two sections of the Resource
Conservation and Recovering Act (RCRA) which also relate to some
types of surface impoundments. A study is being conducted by the
Office of Drinking Water, in conjuncton with the States, to better
define the issues. The purposes of the study include: development
of national data on the number, location, and construction of
impoundments in existence; evaluation of the pollution potential;
obtaining information regarding existing State control programs;
and solicitation of State recommendations for a program to protect
ground water from contamination by surface impoundments.
Only after completion of the study would a decision be made
as to whether (or which portions of) the surface impoundments
will be controlled under RCRA or the Safe Drinking Water Act.
Since there is a possibility that control of some of the surface
impoundments may be included in the UIC program, the system must
be designed with the flexibility to facilitate this circumstance,
should the need arise.
(3) Evolving Regulatory Environment
The underground injection control is an emerging Federal
program. As such it is guided by sections of the Safe Drinking
Water Act for which regulations are still under development. The
results of this situation are;
Forms, and therefore the specific contents, have not been
developed for the Federal permits and self monitoring
reports
Enforcement requirements are not firm, including the means
for assessing the degree or severity of non-compliance
The roles which specific states will assume is not
established
The identification of designated states is not yet complete.
11-14
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The implications of this environment for the UIC management
information system include both the configuration of the software
and the implementation strategy.
In terms of the system configuration, an enforcement function
has been defined for administration of the program. Contacts
with enforcement organizations in EPA have revealed that the
program is too young to permit specification of detailed
requirements. Classic enforcement activities such as analysis
of self-monitoring reports against performance criteria, and
analysis of inspection reports have been identified as applicable
to the UIC program. However, until the data elements to be
included on the Federal permit are defined, and until experts in
the UIC program have agreed upon other compliance measures, the
specific criteria for assessing non-compliance cannot be
established. This information, although not esential for
development of a system concept, is necessary for detail system
design.
The expected volume of activity and who will perform it, are
factors in determining how the system will be implemented, and
indeed, even in selecting among alternative system concepts. For
example, if the majority of designated states were to assume
primacy using their own automated systems, the volume of data to
be handled by the EPA system would be much less than if many
states chose to use the EPA system and/or Region for program
administration. The mix cannot be established even through review
of state system capabilities because many states are waiting
until the regulations are promulgated before deciding on a role.
The implications of the emerging program environment are
included in the analysis of alternatives and implementation
strategies presented in Chapters III and IV. In some instances
of such early programs, an interim software capability, or an
interim or phased implementation strategy is adopted. These
alternatives will be considered for the UIC program.
4. EVALUATION CRITERIA
In evaluating alternative system concepts there are two types of
criteria which are generally considered: effectiveness and cost. The
cost analysis of the alternative concepts is presented in Chapter IV.
The effectiveness criteria are based on the defined requirements and
so are described here. Evaluation criteria identified for the UIC
management information system are:
Minimize the manual burden imposed by the system
Strength of error and accuracy controls
Skill levels required to operate and maintain
11-15
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The ability to respond promptly to recurring and ad hoc
reporting requirements
The ability to handle changing, complex analysis
requirements in support of enforcement and programmatic
needs.
Each of the alternatives described in Chapter III will be
evaluated in terms of these criteria. This evaluation, together with
the cost analyses in Chapter IV, will provide information from which
a recommendation will emerge. Each of these criteria is discussed in
the paragraphs which follow.
(1) Minimize the Manual Burden Imposed by the System
For designated states accepting primacy and for Regions
administering one or more non-primacy States, a significant paper
processing workload is anticipated. Input to the program includes
permit applications, self-monitoring reports, and inspection
reports. Manual approaches can be quickly overloaded with large
amounts of data. Similarly, attempts to relate different types
of incoming data manually will fail if the volumes of data are
significant. The evaluation criterion is the ability of the
system to respond within the limited levels of manpower availabe
in EPA and the States, and within the time required to handle
system inputs and file updates.
(2) Error and Accuracy Control
Manual information systems can be highly accurate if
effective procedures are implemented, and if the volume of data
handled is sufficiently small that the procedures are feasible.
When the data volume expands, automated assistance, including
automated edit functions, is typically required to assure accuracy
of the data base. However, this is only one discussion of this
criterion. The other aspects are the degree to which the system
design provides internal control and the degree to which the
system facilitates maintain data.
(3) Skill Levels Required to Operate and Maintain the System
Although, in general, it is desirable to design as much
capability as possible in the system, this must be balanced by
accompanying maintenance requirements. State and Regional staffs
are usually limited in number and skilled ADP and program
personnel are at a premium. As a result, maintenance must be
minimal in terms of volume and complexity. Similarly, a complex
system requires more skill on the part of users which can
negatively affect the effective response to new requirements. As
a result, the alternatives must be evaluated as to their
simplicity and hence maintainability in the State and EPA Regional
env ironments.
11-16
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(4) Ability to Respond Promptly to Recurring and Ad Hoc Reporting
Requirements
An important objective of most management information
systems is to provide useful reports on a timely basis. To serve
as an effective management tool, the UIC system must be able to
produce such reports as activity summaries, exception reports,
schedules and inventories which are accurate and current.
Although these reports can be produced manually, as the volume
of data increases the feasibility of producing timely reports
quickly disappears. In particular, exception reports are
generally a feature of an automated capability which can scan a
large volume of data quickly to identify the exceptions. The
alternative system concepts will be evaluated in terms of their
ability to provide effective reporting with a primary emphasis
on exception reporting.
(5) Ability to Handle Complex Analyses
The significant analysis capability was identified in the
UIC program functional requirements. These included tracking
enforcement actions and evaluating program effectiveness. Both
of these requirements are driven by parameters, developed by UIC
program staff, which change under the focus and direction of
current program initiations. The staff requires flexible,
powerful capabilities in managing the direction of the program
and in helping to apply proper priorities in program management.
Although these capabilities are more in the realm of desirable
features than necessities, they serve as appropriate evaluation
criteria. The ability of the alternative to effectively provide
these capabilities can be an impartial determinant between two
alternatives which are otherwise equivalent.
Having identified the information requirements, the major issues,
and the evaluation criteria, we are now ready to define the feasible
alternative system concepts which will satisfy the data management
function of the UIC program activity. These are addressed in the next
chapter.
11-17
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III. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE SYSTEM CONCEPTS
-------
III. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE SYSTEM CONCEPTS
In this chapter, system design alternatives for a UIC management
information system are presented. The alternatives focus on the
different degrees of automation possible for the program
administration function performed by a Region for a non-primacy State,
or by a State with primacy. Four alternatives are described, the first
being an entirely manual system. The other three alternatives reflect
increasing levels of automated capability. For each alternative, a
description of the major activities, and the advantages and
disadvantages of the concept are described. Estimated costs for each
alternative are provided in Chapter IV.
In addition to the system design alternatives, system
implementation alternatives have been identified and are described in
Section 5 of this chapter. The system implementation alternatives
consider whether EPA should implement a distributed version of the
UIC Information System or support a simpler, centralized approach.
1. UIC MANAGEMENT INFORMATION SYSTEM ACTIVITIES
Based upon the requirements presented in the previous chapter,
we formed a functional description of the Underground Injection Control
information system. This functional description, presented in Exhibit
III-l, aligns the basic input, output and activities which any UIC
system must support. This functional description will be used as the
basis for the discussionable alternatives in that each alternative
would successfully automate different activities of the UIC
description.
Each of the activities requiring support by an Underground
Injection Control Information system are described briefly below:
Track Permit Applications and Maintain Permits
The system should provide assistance to the administrative
authority in tracking the status of permit applications from
mailing of the application through permit issuance;
development of the permit file upon issuance of the permit;
maintenance of this data as programmed.
Maintain UIC Operations Inventory
UIC systems maintain an inventory of all underground
injection operations, either by well or facility depending
upon the nature of the operating permit. This inventory
must include not only the existing underground injection
operations but also those which are no longer active.
III-l
-------
UNDERGROUND INJECTION CONTROL INFORMATION SYSTEM
PRELIMINARY FUNCTIONAL DESCRIPTION
SOURCE DATA ACTIVITIES OUTPUT RECIPIENT
Facility
0|Nitivn
llllOKlOfk
Pnaal D|M««iinn Tvim
- Much*nk4 Inwgiily Inl
R«mIu
« Injection PfMUNI
VM1 HmA Pimmm*
¦ AnnuUa Pimiiui
Nuiitkilun ol Vialition
Impic lion Fiodiay
- Ownertbip Dili
- Oeia
- Peimit IO Nwntw
- ImiMCiioa Oel*
- Rapo*t D«u
- DJU
¦ lui*CI»OQ PlMUII
Aamriui Pimmu
- W«U Hud Pinwia
- QtiwtJ Stil« >1 Oymiiao
- OpwiWCmdutionlil
Paioiil Condition*
- Ptfml ID Nwnbti
OpwaUoa Type
- Wot] Hasd Pr«utui/£u.
« tigh VataM
h Low Value
a
Con»liaoc» Sclwdiil*
Inspection Schedule
a
Violations OaU
- Type
- Snaiily
- OlItM Desuiptive
Dal*
«
Enlucsawnl Data
paimillDNutrUt
- Vioiation ID Numfce*
Data ol Aciioo
- Action Typa
- Violation Cod*
Old Wall OdU
- (Xmenhip Out
- tocdUoa Dili
- Otign D*li
- Opefatioa Status
- Etc.
Rivmw «id Tl«S
InMaloty StMUMiy
- Nuirtm ol Active Operation*
- Nuntoe* ol InKiivi Opmiiora
- TuUb
Seventy
KHfflil StHWIMfV
Humbw ol AmiUmuum filed
Nuolw ol Permit* louad
Nutabw ol Pwmil MMfclkatiutt
Nun^M ot RnuCalionl
EntMceroent Action SummaJy
Tvi«
Snwily
hoy«n Andyw
TimhIi
Statistical
Cunptiinu Rnuiu
CPA
HdXhjUjHnt
LPA
R«yiui
Piouji
Adm""
I.-IKIO
liivMitwy MjmUMnii
Numbe* ol Addiliom
NuoAtr ol Ddtliom
Pe*mil Status
A|i|ilic«lkm Date
Applkatioo Suits
Application Daemon
luut/Omy Oat*
Pa i mi I NwnlMi
Owne*ttiip
Location
CoudilHMM
Coutplianca S
-------
Develop and Track Inspection Schedule
To assist in assuring that all operations are periodically
inspected, an inspection schedule tracking capability will
be included. Based on an inspection frequency input to the
system, an exception report o£ operations not inspected
within the pre-determined time will be produced on request.
In this way management is provided a tool for checking to
see that no operation needing to be inspected has been
overlooked. This would be an optional capability, utilized
at management's discretion.
Screen and Maintain Inspection Findings
This would support the permit administrator by maintaining
a file of inspection reports for historical purposes and
also to initiate actions as required as a result of the
inspection.
Screen and Maintain Self-Monitoring Reports
Operators will be required to submit self-monitoring reports
on a regular basis. The system should assist in screening
those reports for basic data errors and also for compliance
with permit conditions. The system should also maintain a
history of these reports for compliance analysis for
enforcement purposes.
Initiate and Track Enforcement Actions
The UIC system should support enforcement activities by the
logging and tracking of enforcement actions against
operators. This is both for internal scheduling and tracking
by enforcement and also to maintain enforcement history
actions regarding operations.
Analyze Program Effectiveness
This is a capability activity in terms of the UIC system in
that it requires the ability to statistically and
analytically assess the program information received from
each of the other system activities.
Prepare Periodic Reports and Respond to Special Inquiries
This activity is also one of capability in that the UIC
system should provide the ability to produce the various
periodic reports required by EPA and should also provide
the capability of responding to special inquiries from EPA,
Congress, program administration and others.
III-2
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In the next sections we will present a series of alternatives
with increasing levels of automation with each of these activities.
A brief description of how that alternative will handle each activity
will be described in that section. For the recommended alternative
these activity descriptions are developed in greater detail in Chapter
V.
2. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE 1
The characteristics of UIC system Alternative 1 are shown in
Exhibit II12- Alternative I is a manual system with no automated
capability. It is characterized by:
System management decentralized at each agency
Manually prepare management reports
Hard copy files
Manual procedures.
Descriptions of the activities, management, advantages, and
disadvantages of the alternative system concept follow.
(1) Major Activities
The major activities of Alternative I are performed manually.
These system activities are described below.
Track Permit Applications and Maintain Permits
Permit applications will be sent to those underground
injection facility operators that do not have a permit. A
record is maintained of each outstanding application. This
record includes the date it was sent, to whom it was sent,
and the date it is due. Periodically, the application records
are screened to identify delinquent applications. The
applicant is notified that his application is overdue. A
report identifying delinquent applications is prepared.
When an application is submitted, it is checked first for
data correctness and, secondly, for adherence to both State
and Federal regulations and/or standards. The application
is then reviewed for technical and administrative
qualifications. During this approval process, the status of
each permit application is tracked up to the point of permit
issuance. Once a permit is approved and issued, permit
conditions, operation ownership and location, and other
permit data are recorded onto the application record which
now becomes the Permittee file. As the permit is modified,
the Permittee file is updated.
111-3
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EXHIBIT 111-2
UIC INFORMATION SYSTEM
DESIGN ALTERNATIVE 1
MANUAL
UIC Ooamions
Inventory
Track P«rmn
Aoplicjiiom and
Inventory
Pile
Enforci
Action
Fi»e
Initiate end Treck
Enforcement
Action
Screen end
Meimain
S«l'*Monitorinfl
Reports
System Management
- Decentralized at
Each Agency
Management Reporting
- Manual Status
- Manual Inquiries
- Manual Analyses
Data Management
- Manual Files
Processor
- Manual
Enforcament
Action Notice
Answer
Special
Inquiries
~
¦ Automated tor
-------
Maintain UIC Operations Inventory
The UIC regulations being developed by EPA require that each
state which is authorized to administer the UIC program must
compile and maintain an inventory of all wells and holes
(both injection and non-injection) which may be affected by
underground injection activity within its borders.
Compilation of this inventory involves creating an inventory
record for each underground injection operation. This is
accomplished by posting relevant permit information to the
inventory record for activities which are granted permits
and for those facilities which already have permits. For
facilities which are already permitted, the inventory
maintenance staff may have to access archives in order to
obtain relevant inventory information. In addition to
creating inventory records, this activity also involves
updating existing records. This occurs when the status of
an injection operation changes. These changes may result
from permit modifications, notification of plugging, and
permit suspension or revocation.
Develop and Track Inspection Schedule
Given the projected annual inspection capacity, the number
of underground injection operations, and inspection
priorities and/or frequencies, an inspection schedule will
be developed for each participating organization's field
inspection staff. As priorities change and actual inspection
capacities vary, the schedule is adjusted. The schedule will
also be adjusted when specific requests for inspection are
received. The inspection schedule will identify the
scheduled date, the assigned inspector and the inspection
report due date. By periodically scanning the schedule, the
inspection supervisor can track upcoming inspection,
inspection reports due and overdue, and can in general
monitor the inspection activity. Periodically the
inspection staff will prepare an Inspection Program
Assessment Report.
Screen and Maintain Inspection Findings
In performing field inspections, the permitted conditions
of an operation are tested via integrity tests and results
are reported. Subsequently, the inspection findings are
reviewed and violation(s) are recorded into a Violations
and Compliance record. Subsequently, when a facility
operator notifies the program support staff that corrective
action has been taken, the correction status information
within the Compliance and Violation records is adjusted to
reflect the corrective action. This occurs when the
notification is received and provides for up-to-date
Compliance and Violation records.
111-4
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Screen and Maintain Self-Monitoring Reports
The UIC regulations being developed by EPA state that all
permitted underground injection operations must
periodically report operational compliance to the programs
administrator. This is done through use of a self-monitoring
report. Each operator monitors and completes a report
detailing the monitoring results in terms of pressure and
volume readings. These reports are then submitted to the
program support staff where they are screened against permit
conditions to identify violations. Upon detection of a
violation, a Violation and Compliance record is initiated
by the program support staff. When the operator notifies
the programs administrator that corrective action has been
taken, the Violation and Compliance record is updated.
Initiate and Track Enforcement Actions
Enforcement actions are determined by extracting violation
information from the Violation and Compliance record and
using enforcement guidelines to identify the appropriate
enforcement actions. These actions are based on the type
and severity of the violation.
Once enforcement actions are determined, enforcement action
records are initiated by the enforcement staff. These
records identify the violator, describe the action, identify
the action initiation date, the schedule of events required
to complete the action, and the status of the action. As
enforcement actions are determined, enforcement action
notices and action resolution date schedules are prepared.
The action notices are mailed or delivered to offending
operators. Schedules are prepared and obligatory operator
responses and required enforcement events are tracked. Upon
enforcement action resolution, the enforcement action record
is adjusted with enforcement action status information.
Periodically the enforcement staff will prepare an Activity
report which details all current enforcement activity.
Analyze Program Effectiveness
Periodically the effectiveness of the UIC program will be
measured. This is done by identifying program areas such
as inventory, compliance, and enforcement action, and
performing both trend and effectiveness analyses. Through
these individual functional analyses, overall program
effectiveness can be ascertained. The mechanism for this
analytical activity is analytical tables which are developed
by the program analysts. These tables include formulas and
statistical factors derived from such elements as program
and function goals, objectives and priorities.
111-5
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Answer Special Inquiries
Periodically the programs administrator will receive
requests for information about the program. This information
can pertain to any aspect of the program. These requests
are unique in that they cannot be answered through existing
reporting mechanisms. It will therefore be necessary to
search existing data files, and then compile, format, and
present the information to the requestor.
(2) Systems Management
The systems management for Alternative I will be
decentralized within each affected State administering agency,
or the EPA region which administers the program.
(3) Management Reporting
Management information reports, responses to special
inquiries and analysis reports will be prepared manually.
Reporting frequencies will be quarterly for management
information reports, and annually for analysis reports.
Additionally, special information requests will be responded to
as they are received.
(4) Data Management
The data management used by Alternative I will be manual
data files. These files will include the following information:
Permittee Information - including operator, owner, location,
permit conditions and scheduled milestones where
appropr iate.
Operations Inventory - including information on ownership,
location, contact, classification and permit status.
Compliance History - including information on violations,
conditions violated, permitted values, and actual values.
Violations History - including information on violation
type, severity, date, correction status, detection mechanism,
and enforcement action.
Enforcement Action - including information on action type,
action date, actioii manager, action schedule, and action
status.
(5) Summary of Alternative I
This manual system alternative could be integrated into
State or Regional operations with little or no change to staff
111-6
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skill mix, since skill levels required are consistent with current
staffing. However, there is definitely a limit to the workload
which could be handled by the system. Estimated workloads suggest
that only a State having very little LTIC activity or whose
activities are dispersed over many agencies could handle the
entire program manually. In addition, the manual data
manipulation can result in high error rates and low confidence
in data accuracy. The system represents a labor intensive
capability for producing reports and complex analyses. Again,
depending upon workload, the ability to respond to ad hoc
information requests rapidly is very limited.
3. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE II
Exhibit III-3 depicts the level of automation and characteristics
of UIC system Alternative II. The second UIC system alternative
provides basic automated support for several of the major activities.
The automated features of Alternative II include permit application
tracking and permit¦maintenance and UIC Operations Inventory
maintenance.
(1) Level of Automation of Major Activities
The following paragraphs describe the automation defined by
this alternative.
Track Permit Applications and Maintain Permits
Certain aspects of this activity have been automated under
Alternative II. When an application is sent to a facility
operator the basic information will be key batched into the
computer to create a permit applicant record. This
information includes:
State and Federal Region Code
Applicant Name
Date of Application
Application Due Date
Application Status.
Periodically this file will be scanned and an exception
report listing overdue applications will be generated. When
an application is received, the status is set to "received."
This will occur during a periodic Applicant File update run.
When the application is reviewed and approved, the basic
applicant data is modified and the data from the issued
permit is added thus creating the Permittee File. Permit
information which is added includes:
111 -7
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EXHIBIT 111-3
UIC INFORMATION SYSTEM
DESIGN ALTERNATIVE 2
LEVEL OF AUTOMATION
Ptrmit
Application
Track Pirmii
A pollutions
and Maintain
Permits
Permit
Oau
Permittee
File
Utmuin
UIC Operations
Invtmorv
Archival
Data
Inventory
File
Develop and
Track
Screen and
Maintain
Inspection
Finding*
Inspection
Oau
Compliance
Fil#
Seff
Monitoring
Reports
Screen and
Maintain Self
Monitoring
Report
Violations
File
Initiate end Track
Enforcement
Actions
Enforcement
Action
Pile
Enforcement
Guidelines
System Management
- Decentralized
Management Reporting
- Batch Status
- Manual Inquiries
- Manual Analyses
Data Management
- Conventional Files
Processor
- Single State Processor or
- Individual Agency Processor
Enforcement
Action Nottce
Analyze
Program
Effectiveness
Request
Answer
for
Information
Inquiries
~
¦ Automated for
-------
Permit Number
Ownership/Operator
Operation Classification
Location
Conditions
Schedule
Receiver Formation Data.
The Permittee File is updated periodically when
modifications to existing permits are effected.
Maintain UIC Operations Inventory
As a by-product of the creation of the Permittee record, the
automated system will spin off a UIC Operations Inventory
record. The inventory data will be a subset of the Permittee
data. This information includes:
State and Federal Region Code
Operation Identification
Operation Classification
Operation Location
Operating Permit Basis
Number of Wells
Operation Status
Date of Permit
Date of Inventory.
These inventory records apply to those facilities which will
receive permits when the program commences. For those
facilities that already have permits or are inactive at
program onset, the required inventory information must be
obtained through available archival information. This data
may be compiled manually and key batched into the system,
or it may be in machine readable format provided by a
contractor, as is the case in some states. This data together
with the current data provided by the permitting activity
comprise the automated UIC Operations Inventory.
111-8
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(2) Systems Management
The systems management for Alternative 2 will be
dencentralized at either the State agency or the EPA Regional
office. A single UIC software system will be used. Both the
states and the EPA Regions will use this system to maintain data
files and generate management reports.
(3) Management Reporting
The primary mechanism used in reporting management
information will be batch reports. Batch reports will be
generated on a quarterly basis. Analysis reports, special inquiry
responses, and certain management information reports still
require manual preparation.
(4) Data Management
The data management used by Alternative II will include
several automated conventional data files and several manual
files. The automated data files will include the following
information:
Permittee Identification - including operator/owner name,
location, phone number.
Permit Conditions - including permit basis, permit status,
permit criterion and permit renewal date.
Operation Information - including operation classification,
number of wells and operation status.
(5) Evaluation of Alternative II
This alternative concept provides the capability to handle
the permit and inventory maintenance workload, but the self-
monitoring reports are still processed manually. The self-
monitoring reports represent the largest volume of one type of
input and have a significant impact on manpower requirements.
Accuracy of permit and inventory data can be high, but reports
based on compliance data are limited by manual error rates. Since
an automated capability is being provided, some facility in using
the system would have to be developed if the State/Region does
not already have the staff with these skills. However, the system
is quite straightforward, requiring only minimal capability in
this area. The alternative represents an effective capability
to respond to reporting requirements regarding permits and
operations inventory but inspection scheduling, compliance
monitoring and complex analyses are limited by manual
capabilities.
111 -9
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4. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE III
Exhibit III-4 shows the level o£ automation and characteristics
of UIC system Alternative III. This alternative provides automated
scheduling, compliance and reporting capability in addition to the
previously automated capability of Alternative II. The automated
features of this alternative include inspection scheduling and
tracking, operator compliance monitoring and automated report
preparation.
(1) Levels of Automation of Major Activities
The following paragraphs describe the automation defined by
this alternative:
Develop and Track Inspection Schedule
This activity will be automated in this and all following
alternatives. Program support staff will supply estimated
average inspection time and existing inspection priorities.
This information will be key-batched and entered into the
system. Using this data the system will develop an
inspection date and status for each operation. The
inspection schedule data will be maintained on an automated
file. This file will be read on a quarterly basis with the
compliance data file and the inspection status field will
be checked. Those inspections overdue will be
identified and the system will generate a report to
management which details the overdue inspections. This
activity will be flexible enough to add unscheduled but
requested inspections to the Inspection Schedule data file.
Screen and Maintain Self-Monitoring Reports
This activity will be automated in this and all following
alternatives. Facility operators will be required to
periodically submit self-monitoring reports to program
support staff. The frequency of this submission will be
quarterly, and each self-monitoring report will cover one
month's monitoring activity. The individual monthly self-
monitoring reports will be key-batched and entered into the
system. These self-monitoring transactions will be stored
in a temporary file and the Permittee File will be accessed.
The self-monitoring report transactions will be compared to
the permit conditions and previous reports of that operator
and exception reports will be produced. This will assist
in identification of non-compliance with the permit or other
problems. When a case of non-compliance is identified, the
system will create a Violations and Compliance record. This
record is tied back to the permittee and become part of the
Violations and Compliance data file. The system at the
conclusion of the processing run will generate reports for
111-10
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EXHIBIT 111-4
UIC INFORMATION SYSTEM
DESIGN ALTERNATIVE 3
LEVEL OF AUTOMATION
Permit
Application
Track Permit
Applications and
Maintain
Permits
Ptrmtl
Maintain
LJIC Operations
Inventory
Arehivtl
Data
inventory
Inspection
Schedule File
inspection
Screen and
Impaction
Data
inspection
Findings
Compliance
violations
Screen ano
Maintain Self
Monitoring
Reoort
Srif
Monitoring
Reports
Initiate and Treefc
Enforcement
Anion
Enforcement
Action
Pil
Enforcement
Guidelines
Enforcement
Action Notice
and
Schedule
Analyze
Requeti
for
Information
Answer
Special
Inquiries
Report
Pile
System Management
Decentralized
Centralized
Management Reporting
Batch Status
Batch Inquiries
Manual Analyses
Data Management
Centralized
. . Conventional Files
. . D8MS
Decentralized
.. Conventional Files
e Processor
Centralized
.. EPA Processor
(NCCorWCC)
Decentralized
.. Single State Processor or
.. Individual Agency Processor
¦ Automated for
Pint Time
-------
management including a Violations Report and a Compliance
Repo rt.
Answer Special Inquiries
This activity will be automated in this and all following
alternatives. Based upon a sample of special inquiries that
have been requested, a module will be developed that can
handle a limited number of anticipated inquiries. The
special inquiry request will be key-batched into the system
in a parametric structure, where each set of parameters will
drive the routine that will respond to the particular
inquiry. This module will access system data files in order
to be responsive to the requesting party.
(2) Systems Management
The systems management for Alternative III will remain the
same as the previous alternative.
(3) Management Reporting
This alternative provides additional automated generation
of management reports. These reports will be produced in a batch
processing environment. These reports now include the activities
of inspection and compliance monitoring. Additionally, this
alternative provides batch processing of special inquiries with
automated generation of responses. There still remains some
manual management report preparation, inquiry response
preparation and analysis report preparation.
(4) Data Management
The number of estimated data files increases in this
alternative to include an Inspection Schedule File, and a
Violations and Compliance File. Additionally, there is an
automated temporary inquiry response file which is a basic print
file. These automated files include the following information:
Inspection Schedule
Including information on inspection date and inspection
status.
Violations History
Including information on violator identification, type of
violation, severity of violation, violation detection
mechanism, and violation correction status.
Compliance History
III-ll
-------
Including information on compliance report date, facility
operator, condition out of compliance, permitted value,
reported value, and compliance status.
(5) Summary of Alternative III
This alternative provides an automated capability for
handling all anticipated input reporting. With automated data
handling, error controls should be effective with resulting high
confidence levels for data base accuracy. The system is still
straightforward, but does require that the staff possess some
systems skills. Reporting capabilities include all basic
requirements, such as activity summaries, inspection schedules,
and exception reports. The system is capable of responding
effectively to most ad hoc report requests, but does not possess
a sophisticated analytical capability for extended enforcement
support or program effectiveness analyses.
5. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE IV
Exhibit III-5 graphically presents the level of automation and
characteristics of UIC systems Alternative IV. This alternative
provides automated enforcement support capability and program analysis
capability in addition to the automated features discussed in the
previous alternatives.
(1) Levels of Automation
The following paragraphs describe the automation defined by
this alternative.
Initiate and Track Enforcement Action
This activity requires that the enforcement staff key-batch
and enter into the system a set of guidelines which identify
enforcement actions for certain violations. Once this
information is in the system a violation is identified during
compliance screening, compared to the enforcement
guidelines, and the required enforcement action
automatically identified and reported to the enforcement
staff. When the enforcement staff initiates this action,
they will prepare a notice of enforcement action, the action
date, and any corresponding action schedule. This
information will be key-batched and entered into the system
and an enforcement action history record will be created.
The record will carry all the above data and will include
a status field. Periodically, the Enforcement Action History
File will be read and upcoming events on the action schedule
will be reported as reminders to the enforcement staff.
Additionally, when an event occurs which alters the action
status, this data will be entered into the system and the
record modified. The system will generate management reports
on a quarterly basis.
rn-12
-------
UIC INFORMATION SYSTEM
DESIGN ALTERNATIVE 4
EXHIBIT 111-5
LEVEL OF AUTOMATION
Permit
Application
Permit
Oau
Archival
Data
Track Permit
Application!
and Maintain
Permits
Permittee
Maintain
UIC Operation*
Inventory
Develop and
Track
Impaction
Schedule
inventory
Inspection
Data
Self-
Monitoring
Screen and
Inspection
Finding*
Compliance
Violations
Screen and
Maintain Self-
Monitoring
Report
Enforcement
Guideline!
.
Initiate and Track
Enforcement
Action
Enforcement
FHe
Enforcement
Action Notice
and
Vh.rt,,!.
Analyze
Program
EHeetivenes
Analytical
Tables
System Management
- Decentralized
- Centralized
Management Reporting
- Batch Status
- Batch Inquiries
- Batch Analyses
Data Management
- Centralized
. . Conventional Files
.. DBMS
- Decentralized
.. Conventional Files
Processor
- Centralized
.. EPA Processor (NCC or WCC)
- Decentralized
. . Single State Processor or
. . Individual Agency Processor
Request
for
Information
Answer
Special
Inquiries
~
Automated for
-------
Analyze Program Effectiveness
This activity requires that program analysts develop
analytical formulas and factors to permit the system to
compute program effectiveness and program trends. The type
of analytical formulas and factors is based upon the
projected goals and objectives of the overall program and
the individual functional activities. This data is supplied
by the annual budget process which indicates objectives and
goals. The program analysts will take this information and
develop their formulas and factors using statistical
methods. Once developed, these analytical tools will be key-
batched and entered into the system in the form of Analytical
Tables. On an annual basis the system will measure program
effectiveness by evaluating current figures to date to
projected objectives and applying the analytical formulas
and factors. Additionally, the system will have the
capability to perform trends analyses of the individual
functional activities and the overall program. These trends
analyses may include geographic trends, classification
trends, violation trends, and enforcement trends. The system
will automatically generate analysis reports.
(2) System Management
The system management for Alternative IV will remain the
same as the previous alternative.
(3) Management Reporting
This alternative provides a slight increase in the automated
generation of management reports. These reports include
enforcement activity reports and program analysis reports. Except
for certain special inquiries the reporting function is now
completely automated.
(4) Data Management
With this alternative the number of automated data files is
increased to include an Enforcement Action History file.
Additionally, there will now exist an automated internal
Analytical Table for program analysis. These additional automated
files include the following information.
Enforcement Action History
Includes information on violator, violation, action
description, action date, action status, action manager, and
action schedule.
Analytical Tables
111-13
-------
Includes the analytical formulas and statistical factors
which will be applied in the program analysis activity.
(5) Summary of Alternative IV
This alternative represents the most advanced capability
defined. It is designed to handle the total anticipated input
with strong error controls, and has the ability to respond to a
wide variety of recurring and ad hoc report requests on a timely
basis. The system has now become somewhat complex, however, and
so will require a corresponding advanced level of system skill
to operate and maintain. In particular, effective use of the
program effectiveness and enforcement tracking capabilities
requires some analytical and systems sophistication on the part
of users. The alternative exceeds basic defined system
requirements for a UIC management information system.
6. UIC MANAGEMENT INFORMATION SYSTEM - ALTERNATIVE IMPLEMENTATION
STRATEGIES
Whereas UIC Information System level of automation alternatives
deal with which system functions will be automated, implementation
strategy alternatives primarily deal with how and where system
functions will be implemented. The decision for EPA is whether or not
to offer a distributed environment for the UIC Information System;
that is, offer the States a standard system which can operate locally.
In the analysis, we attempted to identify the possible relationships
for UIC Management that may occur among the States, EPA Regions and
EPA Headquarters. These relationships were defined with regard to the
following:
State Primacy/Non-Primacy
Automated State Capability/No Automated Capability
State Accepts UIC System/Does Not Accept UIC System.
Exhibit III-6 graphically depicts the relationships that were
identified. These relationships include:
Case 1; Non-Primacy State
In this case, the EPA Region would be administering the State
program and would access the UIC Information System through
an EPA national data center.
Case 2: Primacy State/Automation Capability/Accepts
Standard UIC Information System/State facility
Implementation
This case represents the situation where the delegated state
accepts a standard UIC automated Information System and
111-14
-------
UNDERGROUND INJECTION CONTROL SYSTEM
PROCESSING CONFIGURATIONS
Entily
Characteristics
Facility Operator
Responsibility
Stale
Responsibility
EPA Region
Responsibility
National E PA
Responsibility
Federal Reporting
System
1
Non Primacy Slate
Region Administers
Program
Automated System
Source
Data
uerat
K'deiai
Reporting
UIC
System
Data
S v si ~;!!
Key Entry
Files
Data
Transmission
Primacy S late
Automation
Uses EPA Automated
Systemat Stale Level
Source
Data
State
UIC
System
{Standard!
Data
Tiunsniission
ct.'al
nvpoi
System
Federal
Data
Base
Primacy Slate
- No Automation
- Does Not Accept
System
Source
Data
Manual
Files
Data
Transmission
~Z_
rt'deral
deral
porliiu)
Data
System
Primacy State
Automated System
Automated Interface
to EPA Federal
System thru Region
Source
Data
State
UIC
System
(Custom)
Data
Transmission
K(:|»ortiiu|
Data
Base
Primacy State
Mo Automation
Uses EPA
Automated System
National Data
Center
Access Directly
Key
Entry
Source
Data
Data
Transmission
(hi l it I
Fudnml
purring
Data
m
X
X
CO
-I
6)
-------
operates it on State hardware. In this instance, the State
would maintain the detail data files and generate a summary
data file for transmission to the UIC Federal reporting
system.
Case 3: Primacy State/No Automation/Does Not Accept UIC
Information System
A State, having accepted primacy, is required to submit only
summary data to EPA to accommodate the federal reporting
requirement of the program. Therefore, in this case, the
State could periodically present the EPA Region with hard
copy summary data which the Region would then key batch and
transmit to Headquarters for entry into a Federal Reporting
System for UIC information.
Case 4: Primacy State/Automation Capability/Does Not Accept
Standard UIC Information System
In this case, the State would maintain its own customized
UIC system. The State automated system would be able to
provide summary data for the Federal Reporting System in
machine readable format.
Case 5: Primacy State/Automation Capability/Accepts
Standard UIC Information System/EPA Facility Implementation
In this case, the State would have the automated capability
to access the UIC Information System and State data through
an EPA national data center. The State data base would be
accessible only by the State until the State formally
releases data to the Federal Reporting System.
These five cases represent the set of possible State-Region-
Headquarters relationships which could occur in a distributed
environment. There are of course variations of these five cases, for
example, the situation where multiple state agencies administer
portions of the program and each has automated capability.
Within this framework there are basically two approaches which
EPA can take to provide automated assistance to the delegated States.
The Agency can make the system available to the States via the State's
own telecommunications capability and one of the EPA national data
centers, or EPA can support implementation of the UIC Information
System in delegated States which request this. The decision, from
EPA's perspective, is whether EPA should offer the latter capability.
Because EPA must support Case 1, it must offer centralized capability
and thus could easily support Case 5. However, to support Case 2, EPA
must make an additional investment to develop a distributed capability.
Therefore the two basic approaches are:
111-15
-------
Because EPA must support Case 1, it must offer centralized capability
and thus could easily support Case 5. However, to support Case 2, EPA
must make an additional investment to develop a distributed capability.
Therefore the two basic approaches are:
Centralized Processing Approach
Where system software and data bases reside only at a
national EPA data center, but are segregated by State.
Distributed Processing Configuration
Where system software and data bases reside either
nationally or locally at the States depending on the State
option.
These alternatives are discussed below.
(1) Alternative 1 - Centralized Processing Approach
The centralized alternative is characterized by having the
UIC Information System software and individual State data bases
resident at an EPA national data center, either NCC or WCC.
Data Collection and Data Entry
Each State or administering Region would be responsible for
collecting and preparing the input data for entry into the
UIC Information System. This process consists of
transferring raw data onto coding sheets, and batching these
input data forms, transformation into machine readable
format, and remote transmission to the EPA data center.
Data Processing
In the centralized approach the system software would reside
at an EPA national data center. Therefore all system
processing and data manipulation would occur at the data
center, however, the processing and data bases would be
segregated by State. System output will be spooled and
transmitted to the RJE terminals at the States and Regions
where the printed output will be available for program staff.
The UIC system is a batch processing system which will
provide overnight turnaround.
System Interfaces
The UIC Information System will interface with a Federal
Reporting System for the national UIC program. The Federal
Reporting System would also be resident at the national EPA
data center. The UIC Information System would generate
II1-16
-------
summary data files for each State, once approval by the
State, for entry into the Federal Reporting System.
(2) Alternative 2 - Distributed Processing Approach
The distributed processing approach applies to those states
which are authorized to administer the UIC program and have
automation capability. For those states who prefer their own
system, EPA would implement the UIC Information System at State
facilities. All State UIC information processing will be
performed within the States, either at a single data center, or
at individual agency data centers when multiple agencies are
involved. This processing alternative is characterized by the
data and software residing within the State, with only Federal
report data being output from each State to corresponding Regional
Offices.
Data Collection and Preparation
The responsibility for collection and preparation of the
input data in the distributed environment will rest with
the agency or agencies administering the UIC program. When
the processing is done at a central data center within the
State, the multiple agencies will forward their data to a
central coordination point for batching in preparation for
data entry. If processing resides with individual agencies,
they will prepare and batch their own data for entry into
the system.
Data Processing
The data processing in the distributed mode will occur at
the State level. Within each State, however, the system
processing and data manipulation may occur at one or several
points, depending upon whether there is a single central
data center operation or an individual agency data center
operation. Processing would utilize the UIC Information
System provided by EPA and maintained by the State.
System Interfaces
The UIC system will interface with a Federal Reporting System
for the national UIC program. The UIC Federal Reporting
System will be a centralized system. Therefore, the
interface mechanism to the Federal system will be an
automated data file which contains the summary level data
required by EPA. The media would be magnetic tape which can
be submitted to the EPA Region for transmission to the
national data center for inclusion in the Federal system.
There are significant cost and operational impacts of the two
approaches, both to EPA and the States. These are addressed in
Chapter IV.
111-17
-------
COST ANALYSIS
-------
IV. COST ANALYSIS
This chapter describes the methodology developed by Arthur Young
& Company to perform cost analyses of the alternative Underground
Injection Control Information System (UIC) designs proposed to the
EPA Office of Drinking Water (ODW), and presents the results of the
cost-effectiveness analyses conducted on each of the alternative
system concepts. Discussed below are the following topics:
General Assumptions - A number of general assumptions
applicable to all of the alternatives were made. These
assumptions are presented with a brief description of the
rationale for their inclusion.
Cost Strategy - In order to estimate necessary and relevant
costs for evaluating alternative system concepts and
alternative implementation strategies, a definition of a
cost unit was developed.
Cost Matrix - A cost matrix was developed to graphically
represent the detailed computations involved in each cost
analysis, and to permit evaluation from varying perspectives.
Alternative Workload Assumptions - A number of workload
assumptions are presented. These are used to develop data
entry volumes and file size statistics used in the cost
analysis.
Alternative Cost Analyses - Each alternative considered for
UIC is supported by specific assumptions and the matrix
charts delineating the associated costs.
Alternative Effectiveness Analysis - Each alternative
possesses unique qualitative attributes. In order to
highlight these attributes, each alternative was evaluated
in terms of its strengths. Consequently, a management impact
chart for each alternative system design is presented
following the alternative cost analyses.
1. GENERAL ASSUMPTIONS
In order to ensure consistency in the methodology used for the
cost-effectiveness analysis of alternative system concepts, a master
list of general assumptions was developed. These general assumptions
provide a standardized base utilized in the development of cost
algorithms for each cost-effectiveness study. In some instances, the
nature of certain system alternatives necessitated modification of
general assumptions. These modifications, as well as additional
components incorporated into the algorithms, are contained in the
specific assumptions pertaining to each alternative.
IV-1
-------
Assumptions regarding system design and development, system
implementation, and system operations costs are categorized as
personnel resources, computer resources and supplies/other. The
General Assumptions are summarized in Exhibit IV-1 on the following
page, and explained below.
(1) Assumptions Regarding System Design and Development Costs
Personnel Resources - Assumptions related to personnel
resources are categorized as costs relative to contractor
and EPA personnel. We assumed that contractor personnel
will have responsibility for performing all aspects of the
UIC system development life cycle (i.e., detailed system
design, program specifications, program development,
documentation preparation, and system test), while the EPA
personnel contribution will be concerned with project
management and supervision of all system design and
development functions.
Contractor Personnel - Contractor personnel can be
grouped into three major categories, consisting of
systems analysts, programmer/analysts, and programmers.
Systems analysts are primarily responsible for the
detailed systems design, preparation of manuals and
related documentation, development of system
procedures, and design of user training programs.
Personnel in this category are assumed to cost $15 per
hour. P rogrammer/analysts cost approximately $12 per
hour and are responsible for the training of EPA system
users and the development of program specifications as
well as providing a portion of their time (25%) to
system testing. Also, they are responsible for
providing forms design and documentation for the manual
system. P rog rammers who perform the technical
functions (i.e., basic programming, testing, etc.)
required by the systems are estimated to cost $10 per
hour. Programmers are responsible for the actual
program development (writing, testing, debugging, etc.)
and the major portion of system testing. These hourly
rates include allowances for supervision, fringe
benefits, and overhead.
EPA Personnel - In the following description, all hourly
salary rates are calculated using the Federal fringe
benefit and overhead factor of 24.4%. As mentioned
above, it is assumed that EPA will supervise contractor
personnel during the system development life cycle.
The EPA Project Officer will be responsible for
providing guidance to the contractor, in addition to
reviewing and accepting all project deliverables. The
amount of project manager participation is assumed to
be 25% of the total calendar hours expended by the
IV-2
-------
EXHIBIT IV -I
ASSUMPTIONS REGARDING SYSTEM DEVELOPMENT AND OPERATIONS COSTS
Cost
Items
Cost Element
Components
Assumptions
Personnel
Resources
Contractor Personnel
Oetailed System Design Performed
by Contract Systems Analyst - Rate S15/hour
Programming Specifications Developed
by Contract Programmer Analyst Rate S12/hour
Program Development by Contract
Programmer Rate SlO/hour
System Testing Performed by Programmer
Analyst (25%) and Programmer (75%). (Both
Contract Personnel)
Manual Procedures/User Training Performed
by Contract Systems Analyst
Data Conversion and Prototype Operation
Performed by Contractor Personnel. Using
Programmer Analysts
EPA
Personnel
a Training
Oata Conversion
Parallel Operation
Data Preparation
Project Management by EPA Personnel Will
be 25% of the Time Spent by Contract Personnel
EPA Rates are:
Supervisor GS 13 5
Analyst GS 11-5
Clerk - GS 5 - 3
Fringe Benefits - 24.4%
Civil Service Salaries Increase 5%/Annum
EPA Performs System Maintenance
Computer
Resources
CPU Time
Oata Storage
c Communication
Cost for Remote
Terminals
CPU Time Costs S932/hour
Oata Storage Charges are SSO/Month/Disk Pack
plus S5 per Mount
Connect Time Cost is S21/hour
Supplies/Others
Documents
e Computer Supplies
T ravel
Reproduction Cost is 5 cents/page
Printer paper Cost is 1 cent/page
Cards Cost SI2/box of 2000
-------
contractor. The hourly rate for the EPA project
manager, at the assumed pay grade of GS-13/5, is $17.63.
Computer Resources - Assumptions related to computer
resources have been categorized as costs relative to
processing time, data storage, and communication costs. For
purposes of costing we used the new WCC rates (March 1, 1978)
wherever relevant. The Computer Resources section is not
applicable to Alternative I - UIC Manual System.
Processing Time - This variable is computed using the
WCC computer usage unit (CUU) algorithm:
# of CUUs = 2.3513 (CPU Seconds) + .03462 (EXCPS) +
.00135 (CPU Seconds) (Region Requested) +
.00159 (Tape EXCPS)
Using this algorithm for WCC priority 2, which costs
11C per CUU, estimates were made based on the following
assumptions :
The average CPU time required per compilation is
10 seconds; per test run is 20 seconds; and per
production run is 40 seconds
The average number of EXCPS per test run is 500;
per production run is 100,000
There are no tape EXCPS.
Data Storage - We estimated storage costs based on the
WCC private mountable disk storage cost of $50 per
month rental and $5 per mount of the disk.
Communication Cost - Communication costs deal primarily
with the amount of time necessary to enter data into
the system and to receive information from the system
via a remote terminal. Consequently, this cost is only
associated with those alternatives that require an on-
line environment. Remote terminal (on-line)
communication costs were based on the low speed connect
time cost of $21 per hour.
Supplies/Other - Assumptions related to supplies and other
items have been categorized as costs for document production
and computer generated printouts.
- Document Production - Contractor document production
costs were based on rates of $6 per hour for secretarial
personnel time and $0.05 per page for reproduction
costs. The actual pages of documentation and graphics
were based on the requirements of each system
alternative.
IV-3
-------
Computer Generated Printouts - A standard cost of $0.01
per page was used for printer paper cost. The actual
number of pages printed was based on the requirements
of each system alternative.
(2) Assumptions Regarding System Implementation Costs
Assumptions applied to implementation cost estimates are as
follows:
Personnel Resources - Assumptions related to contractor
personnel costs for the UIC system design and development
are also applied to implementation with some additional
assumptions:
EPA Personnel - In the description of EPA personnel
for system design and development costs, we referred
to the EPA project management function and pay rate.
During the UIC system implementation phase, EPA
personnel, in addition to the project management
function, participate as trainees. Trainees are
categorized as computer staff, clerical staff, or
professional staff trainees. The following details the
average rates for each staff type and are assumed to
be opportunity cost estimates for EPA headquarters, or
regional and state program personnel.
Computer staff members are assumed to cost $12.38
per hour
Clerical staff members are assumed to cost $6.36
per hour, or the equivalent of the GS 5/3 pay rate
with fringes and overhead
Professional staff members are assumed to cost
$12.38 per hour.
Computer Resources - Assumptions related to computer
resources for UIC system implementation are the same as for
system design and development costs.
Supplies/Other - Assumptions related to supplies and other
costs are the same as for system design and development
costs.
(3) Assumptions Regarding System Operations Costs
System operating costs vary with the operational
configuration within each system design alternative.
Computer Operations - Computer operation assumptions for
system operations costs are the same as for UIC system design
and development computer operation costs.
IV-4
-------
Manpower Operations - Assumptions relating to manpower
operations are based on the operating requirements for each
system alternative. The following lists the uniform
assumptions made pertaining to system operations:
Data Entry - We assumed that data entry will be
performed by a contractor with the coding rate equal
to 3,000 characters per hour and a keypunch rate of
10,000 strokes per hour. Data entry personnel are
assumed to cost $6 per hour for coding and $8 per hour
for keypunching.
Computer Support Staff - We assumed that for each level
of the UIC program implementation (i.e., EPA HQ, Regional
or State level) varying amounts of ADP support staff
will be required. These ADP staff personnel are assumed
to cost $12.38 per hour or the equivalent of a GS 11/5.
Supplies - Supply costs were estimated using the assumptions
for UIC system design and development costs.
System Maintenance - The following details the assumptions
which comprise system maintenance costs.
Computer Resources were estimated on the basis of one
system maintenance action per month.
Management Costs were estimated to be 25% of the total
computer support staff costs for each alternative.
2. COST STRATEGY
Because of the complexity of the decisions which face ODW in
analyzing its alternatives for the Underground Injection Control
Information System, we have presented the costing in two steps, oriented
to the specific decisions. That is, we first make the decision as to
what level of automation should be developed by EPA. This is presented
in terms of the design and development of a system for EPA's own needs
in administering State programs through the Regions. Whether the
system is centralized or distributed does not significantly impact
the alternative concepts analysis. Given the level of automation
appropriate to EPA, we then proceed with the decision as to whether
EPA should invest the additional funds in developing a distributed
system to support the States who would prefer this approach.
In developing the cost to support the first decision, that is the
appropriate level of automation, we have developed the following cost
estimates for each alternative:
The costs for the design and development of the Underground
Injection Information System from detailed design through
systems test.
IV-5
-------
The cost to EPA Headquarters for the prototype
implementation and operational maintenance of the system.
The additional implementation and operational costs for a
typical small State administered by a Region (where small
is defined as a State containing approximately 1,000 active
UIC operations).
The additional implementation and operations cost for a
large State supported by an EPA Region (where large is
defined as approximately 35,000 UIC operations).
The first two of these costs is basically the fixed cost that would
be incurred for the design and operation of a UIC Information System,
where the latter two are incremental costs for the implementation and
operation of each State within the Region. These costs are presented
for both the base estimates and the full life cycle costs.
A cost analysis of alternative implementation approaches was then
made for the recommended system concept. The implementation approaches
are: centralized - provide access to the EPA software for States with
primacy; distributed - implement the software on State facilities for
States with primacy. Costs for the centralized concept were developed
during the analysis of alternative system concepts. A comparative
analysis of this approach to the distributed approach must be made.
To accomplish this, we estimated each of the above cost components for
the case in which EPA would design, develop, implement, and support
the system on a distributed basis. This would require EPA to implement
and support operation of both the centralized system and distributed
State systems.
In the costing of the distributed systems, costs were included
for the additional development costs for the portability of the
distributed system, additional training for the State programs, and
additional system maintenance cost in both EPA and the States. We
decreased some cost items, such as the telecommunications costs, which
would not be incurred by a State utilizing the distributed system.
In order to provide EPA with some basis for the magnitude of the
cost impact of the centralized vs. distributed approach, while
considering all of the various options the States would have in terms
of primacy, we developed a series of three scenarios for the UIC
program. These considered several different possibilities for the
program in terms of the decisions of the designated States who accept
primacy. These scenarious ranged from an assumption that many of the
States would proceed with their own systems, to the potential that
many of the States would participate with EPA in the UIC Information
System.
IV-6
-------
3. COST MATRICES
To present the cost analysis of each system alternative, two
Alternative System Cost Estimate matrices are utilized. These
matrices, which are included as Exhibits IV-2 and IV-3 on the following
pages, cross-tabulate the cost elements of the system life cycle. In
the following paragraphs, the component parts of the matrices are
described. However, presented first is a discussion of out-of-pocket
expenses and opportunity costs.
The total of each system life cycle phase is categorized as either
an out-of-pocket expense or an opportunity cost.
Out-of-Pocket Expenses - Out-of-pocket expenses represent
those expenses which will be incurred through contractual
services or through direct purchases. These expenses must
be included in the budget and eventually necessitate the
issuance of Treasury checks or, in the case of computer
resources, an internal transfer of funds.
Opportunity Costs - Opportunity costs may not be additional
dollar expenditures. Rather, in order to evaluate competing
alternatives on an equal basis, these costs must be included
as they represent a restriction of existing resources, in
effect, lost opportunity. The opportunity costs in this
analysis are those costs related to personnel. Measurable
units, such as the number of hours required of professional
staff, are expressed in dollars to permit a comparative
evaluation. It is important to note that, although
opportunity costs are not necessarily an additional dollar
expenditure with a direct budget impact, they will become
direct if there are no transferable resources available.
The other dimensions of the matrix are the strategies and cost
components. The Systems Design and Development costs are one time
expenditures which are EPA Headquarters specific. They are specific
in the sense that all activity related to detailed design, programming,
and testing, of the selected alternatives is entirely the
responsibility of EPA Headquarters. These costs are collected in
Exhibit IV-2.
Implementation costs and operating costs for EPA Headquarters
and for each State using the system will be collected utilizing Exhibit
IV-3. There are two points which must be addressed in the use of the
Exhibit IV-3 cost matrix. Although implementation costs are
traditionally assumed to be one-time in nature and would normally be
presented along with system design and development costs, the
implementation costs associated with each alternative are State
specific and will vary depending upon the size of the implementing
state, as is the case for operating costs.
The second point to be made with respect to Exhibit IV-3 is that
it will be used three times for each alternative. Two Exhibit IV-3
matrices will present the implementation and operating costs for the
IV-7
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM DESIGN AND DEVELOPMENT
ALTERNATIVE
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out of Pocket
Expenses
Opportunity
Costs
Total
Detailed
Systems
Design
Program
Specifications
Program
Development
Documentation
Preparation
System
Test
Total
Development
Costs
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ADMINISTRATIVE AGENCY / EPA HEADQUARTERS
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE
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administering agency (large and small), while the third Exhibit IV-3
matrix will be used to present the implementation and operating costs
for EPA HQ. This distinction is made because some EPA implementation
and operation costs are independent of number of States, and thus fixed
in relation to number of States accepting the System.
As indicated in Exhibit IV-2, the cost elements of the design and
development phase are:
Detailed system design
Program specifications
Program development
Documentation preparation
System test.
These are costs incurred to proceed from the feasibility study through
system test, that is up to prototype operational testing.
The cost elements of the next phase, the implementation phase
illustrated in Exhibit IV-3, are:
Data conversion
User Training
Prototype Operations.
The cost elements for system operation also are included in the Exhibit
IV-3 cost matrix. These costs elements are:
Data entry and update
Processing and reporting
Management and analysis
System Maintenance.
These costs include all personnel expenditures directly attributable
to the system processes required by the UIC system whether automated
or manual. This cost matrix also provides operating costs for both
an annual basis and for an assumed five years of system life. The
life cycle cost represents the sum of implementation and five year
operations costs. The cost analysis technique is illustrated in
Exhibit IV-3A.
Cost estimates for an initial feasibility study of a system of
this type are not sufficiently accurate to permit a valid estimate of
IV-8
-------
ALTERNATIVE DESIGN AND
DEVELOPMENT COSTS
ALTERNATIVE SYSTEM CONCEPTS
COST ANALYSIS
EPA HEADQUARTERS ALTERNATIVE
IMPLEMENTATION AND OPERATIONS
COSTS
HEADQUARTERS
EPA ALTERNATIVE
COST SUMMARY
-------
staff resources. Personnel costs were built up from manhour and volume
estimates and are not a suggested means for estimating staffing
requirements. The change in estimated personnel costs from alternative
to alternative will give an indication of whether personnel resource
requirements are expanding or diminishing. Once the general and
detailed designs of the recommended alternative are complete, reliable
staff estimates should be possible.
4. ALTERNATIVE WORKLOAD ASSUMPTIONS
Each of the UIC system alternatives proposed to ODW were subjected
to an alternative cost analysis which is presented in Section 5 of
this chapter. Supporting each analysis are the general workload
assumptions used in analysis of each system alternative. These
workload assumptions include:
File Sizes - For costing purposes, the following files and
file sizes were uised :
Permittee File -- 300 characters per record; 1,000
records for a small State; 35,000 records for a large
State
Inventory File -- 80 characters per record; 10,000
records for a small State; 500,000 records for a large
State
Violations and Compliance File -- 160 characters per
record; number of records estimated between 10 and 200
Enforcement Action History File -- 80 characters per
record; number of records estimated between 2 and 50.
Project Management Costs - Both EPA and contractor project
management costs were calculated based on the number of
calendar hours required to perform a task. For instance, if
a task were estimated to require 400 personhours to complete
and four persons were assumed to work on this task, the
number of calendar hours required for task completion would
be 100 hours (provided, of course, the longest sub-task
required no more than 100 hours). Thus, assuming EPA project
management consumes only 25% and the contractor project
management consumes 10% of the total time expended per task,
EPA project management in this case would equal 25% of the
total calendar hours or 25 personhours and- the contractor
project management cost would be 10% of the total calendar
hours or 10 personhours.
Data Entry Assumptions - The largest data entry expenditure
for the UIC system occurs during the system implementation
phase. Dependent upon the system design alternative, State
manual files must be converted to automated and uniformly
IV-9
-------
formatted data files. This data conversion effort requires
that each file record be coded onto a predetermined coding
sheet prior to data keypunching. Implementation of the UIC
system will, in all cases, include the conversion of the UIC
operations inventory information, including injection wells,
producing wells, and abandoned wells. The large/small
volumes include the following inventory breakdown:
Smal 1 - 10,000 wells; 1,000 injection wells; 1,200
abandoned wells; 7,800 producing wells
Large - 500,000 wells; 35,000 injection wells; 300,000
abandoned wells; 165,000 producing wells.
We assume that violations, compliance and enforcement
information will be incorporated as it is developed after
the system becomes operational.
5. ALTERNATIVE COST ANALYSIS
Each of the alternative conceptual designs and implementation
strategies discussed in Chapter III was subjected to a cost analysis.
Supporting each analysis are specific assumptions for each alternative.
Each alternative system cost has been estimated over the system design
and development phase (detailed system design, program specifications,
program development, system testing, and documentation preparation)
and the implementation, operation and life cycle phase. Within each
alternative, costs are broken down into resource costs (manpower, CPU
time, supplies, etc.) for each phase. The design and development costs
are presented as a separate cost unit. The implementation, operation
and life- cycle costs are presented in terms of large volume and small
volume cost units for each alternative concept.
(1) UIC Alternative I Conceptual Design
In developing the manual system costs of Alternative I, we
have made the assumption that the administering entity is a single
agency. Discussed below are the other specific assumptions and
cost analyses for the UIC Alternative I (Manual System)
Specific Assumptions The following are the specific
assumptions used to develop Alternative I costs:
Required Files - The following are the required UIC
system files, which will be created and maintained
manually:
Permittee File
Inventory File
IV-10
-------
Violations and Compliance File
Enforcement Action File.
Reports Generated - These reports will be prepared
manually by the professional staff and the clerical
staff of the administering entity.
Inventory Reports - Each administering entity will
produce and update, periodically, inventory
reports of underground injection wells and
fac ilities.
Permit Status Reports - Each administering entity
will produce and update reports of underground
injection facility operations permit status.
Inspection Status Reports - Periodically, a report
showing the status of the inspection program will
be produced and maintained by this system.
Data Entry and Update - The initial entry of manual
inventory information will involve 10,000 records for
a small Region and 500,000 for a large. In terms of
data entry activity this means logging the record,
screening it, and filing it. Additionally, it involves
typing inventory lists for management
Training - Under Alternative I, training will be
provided for the professional and clerical staffs of
the administering entity. The type and number of staff
include the following:
Small Volume Administration
2 Clerk/Typists
2 Program/Analysts
1 Program Supervisor
Large Volume Administration
8 Clerk/Typists
4 Program/Analysts
1 Program Supervisor.
This staff configuration addresses only those types
and numbers of staff which may be involved in one or
more aspects of system maintenance; it is in no way an
estimate of the staffing requirement.
IV-11
-------
The duration of the training session for the clerical
and professional staff.is assumed to be one week,
regardless of the volume size. It is assumed that
contractors will conduct training sessions.
Processing and Reporting - Under Alternative I,
processing and reporting will be done manually.
Processing includes screening self-monitoring reports
submitted by facility operators, identifying violations
and follow-up. This will be done by the program
analysts. Clerical support will include logging and
filing the self-monitoring reports and typing various
reports which are initially prepared by analysts.
Volume figures for processing and reporting are:
4,000 self-monitoring reports per year for small
140,000 self-monitoring reports per year for
large.
Management Analysis - This consists of analyzing and
reviewing system generated reports and other program
documents. It is entirely a manual operation.
Alternative System Cost Estimates - Alternative I system
costs are presented on Exhibit IV-4, IV-5a, IV-5b, and IV-
5c. Exhibit IV-4 presents the system design and development
costs for Alternative I. Similarly, Exhibits IV-5a through
IV-5c present the implementation and recurring operational
costs for Alternative I in terms of five-year life cycle
costs. The first two exhibits, IV-5a and IV-5b, present the
incremental costs for implementing and operating the system
in a State. The last, IV-5c, presents the fixed EPA
Headquarters costs required to implement and operate the
system-independent of the number of such systems
implemented. This is presumed minimal in this alternative
because of the manual nature of the system.
(2) UIC Alternative II Conceptual Design
Discussed below are the specific assumptions and cost
analyses for the UIC Alternative II (Basic Reporting System)
conceptual design.
Specific Assumptions - The following are the specific
assumptions used to develop Alternative costs.
Number of Computer Programs - The following are the
major categories and number of programs required by
this alternative:
IV-12
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM DESIGN AND DEVELOPMENT
ALTERNATIVE DESIGN ALTERNATIVE I - MANUAL SYSTEM
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out of Pocket
Expenses
Opportunity
Costs
Total
Detailed
Systems
Design
22,500
300
2,800
_ _
1,000
2 3,500
3, 100
26,600
Program
Specifications
Program
Development
..
--
Documentation
Preparation
20,000
300
2,100
5,000
25,000
2,400
27,400
System
Test
..
Total
Development
Costs
42,500
600
4,900
6,000
48,500
5,500
54,000
m
X
I
oo
<
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ADMINISTRATIVE AGENCY
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
alternative . l_^_Marmal - Small-
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol Pocket
Expenses
Opportunity
Costs
Total
Implementation
Data
Conversion
9,4 00
Training
3,600
500
1, 700
3, 600
7 ,200
2 , 200
Prototype
Operation
1 1 . 400
9 .600
1,500
1,500
21,000
22,500
Total
Implementation
3,600
11,900
11,300
5,100
3 , 700
23,200
31,900
Fits! Year
Operating
Dili Entry &
Update
-X,.0.0.0.
8, 300
son
100
100
1.500
1,600
Processing &
Reporting
5, 100
1,200
1, 200
13,400
18.800
14,600
Management
& Analysis
-4-r-lOO-
500
-14-, 7-00.
1 00
1 00
18.900
Syilem
Maintenance
1, 200
100
100
1, 700
1,800
Total First
Year
13,900
21,500
1, 500
1, 500
35,400
36,90 C
Life Cycle
Opeiating
Data Entry ft
Update
_5., -50D-
45,900
_Z,-8DD
28.200
600
600
8. 300
8, 90C
Processing &
Reporting
6 , 600
6,600
74,100
80,700
Management
& Analysis
22,700
81,200
600
600
LO 3,90C
9. 400
L04,50T
10.00(
System
Maintenance
"> «nn
6, finn
600
600
Total
Life Cyda
3,600
88,800
130.100
13,500
17,100
218,90C
i: 2 36 , 0C
-------
ADMINISTRATIVE AGENCY
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE ..I.-. LARGE/MANUAL
Cost
Elements
Pcisoiinul (U'soutces
Cuiii|>utei Mesuutces
Totals
Conlrtcioi
EPA
Computet
Suppoil
EPA
Cleiical
EPA
Ptufeiiitjual
Piocniiug
Stuiage
Cuiiiuiuuicaliuti
Suppliet/
Uthci
Out ol Pocket
Eipemei
Oppotiunity
Cinh
Total
Dftti
Cooveiiiun
liiiptcmeiitatiui)
Ttaiuiiig
Ptololype
Qpeialion
3,600
2,000
273,000
2,700
41,300
-
..... .
3,900
7, 500
7, 500
7,500
4,700
314,300
12,20C
321,80C
Total
Implementation
3,600
275,000
44,000
11,400
15,000
319,000
334,00C
Data Entiy &
Update
76,000
1,100
3_00
300
.77,100
7 7,40C
Ptoceiiiiig &
Repotting
26,400
171,500
4, 500
4, 500
197,900
202,40C
Fhsl Yeai
Opeialauy
Management
& Analyiii
8,100
18,700
300
300
26,800
27,IOC
Syilem
Maintenance
2,500
1,200
100
100
3, 700
3 , 80C
Tolid fin!
Veil
113,000
192,500
5,200
5,200
305,500
310,70C
D«la Culiy &
Update
419,900
6,100
1,7 00
_ 1,700
426,000
427,70C
Piecciiing &
nepuiliiif
145,900
947,600
24,900
24,900
10'->3. 5
1118.4
Life Cycle
Opeialing
Mauagemcul
& Atulyiil
44,800
103,300
1,700
1,700
148,100
149,80C
Syileiu
Maintenance
13,800
6,600
600
600
20,400
21,00C
Tolal
Life Cycle
3,600
899,400
1107.6
40,300
43,900
2007.0
2050.9
-------
EPA HEADQUARTERS
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE EPA - FIXED COST
Cost
Elements
Peisuiincl flcsouiccs
Cumpiiiei llesuuices
Suppliet/
Othci
Totals
Coatiactoi
EPA
Computet
Suppoit
EPA
Cltncal
EPA
Piuleliiunal
Piocettincj
SluNge
Cuiiiinuiiicaliuii
Out ol Puckcl
E upeiun
Oppuitunity
Cutis
Tuial
Implementation
Oala
CoaveiiiuQ
If lilting
Pialulype
Opeiatioo
-
Told
Implementation
Fiist Ycai
Opoiatiiig
Data Euliy &
Update
Piucciiing &
Repotting
Management
& Analyih
Syitein
Maintenance
200
400
- - ¦
.. . . .
. .....
100
100
600
700
Total Finl
Veai
200
400
100
100
600
700
Life Cycle
Opciatiug
Data Culiy &
Ujidali
Piucetting &
Deponing
Managcmeut
& Analyiii
Syileiu
Maiuteuanc*
. . _
600
. .
3 300
3900
1100
2200
600
Total
iile Cycle
1100
2200
600
600
3300
3900
<
tn
O
-------
1 Edit/Update Module
1 Report Generator
1 Federal Data Extract Program
Required Files - The following are the automated files
required to be kept on disk(s) by Alternative II and
associated configurations:
Permittee File
Inventory File
Reports Generated - The following are the major
Alternative II reports generated:
Various Error/Diagnostic Reports - one per
edit/update program execution
Permit Status Reports - generated monthly for
state level administrative agencies, and quarterly
for EPA regional offices
Inventory Reports - generated annually for States,
Regions and EPA Headquarters
UIC Annual Report - generated annually for EPA
Headquarters, Congress, other agencies.
Data Conversion - This consists of manual conversion
of the operations inventory. For a small volume State,
this entails 10,000 records while for a large volume
state it entails 500,000 records. The activity consists
of coding and keypunching the information. We have
assumed this will be done by a vendor.
Data Entry and Update - The following are the data
entry volumes assumed for Alternative II:
Coding/Keypunching of Permittee Information -
Dependent upon the entity size, this consists of
those new operations and changes to existing
operations which are posted to the files. We have
assumed that this volume will be 700 records for
small and 3,500 records for large. The incoming
data will be coded and keypunched by a vendor.
T raining - It was assumed that two members of the
contractor staff will conduct the training sessions at
the administering entity. Three training sessions will
be conducted, with one for the computer staff, another
IV-13
-------
for clerical staff and one for the UIC programmatic or
professional staff. Also, it was assumed that EPA
Headquarters will be responsible for out-of-pocket
expenses.
Alternative System Cost Estimates - Alternative II system
design and development cost and implementation, operation
and life cycle costs are presented in Exhibits IV-6 IV-7a,
IV-7b, and IV-7c.
(3) UIC Alternative III Conceptual Design
Discussed below are the specific assumptions and cost
analyses for the UIC Alternative III (Tracking/Compliance System)
conceptual design.
Specific Assumptions - The following are the specific
assumptions used to develop costs for Alternative III:
Number of Computer Programs - The following are the
major categories and number of programs required by
this alternative:
1 Ed it-Update Module
1 Compliance Monitoring
2 Report Generators
1 Federal Data Extract Program
Required Files - The following are the automated files
required to be kept on disc(s) by Alternative III and
associated configurations:
Permittee File
Inventory File
Violations and Compliance File
Reports Generated - All reports listed under
Alternative II will be used by this alternative. In
addition the following reports will be generated:
Inspection Schedules - generated annually and
updated monthly to reflect changes which have
occurred.
Inspection Reports - generated monthly for
inspections scheduled for the coming month.
IV-14
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM DESIGN AND DEVELOPMENT
ALTERNATIVE
DESIGN ALTERNATIVE II - BASIC REPORTING SYSTEM
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol Packet
Expenses
Opportunity
Costs
Total
Detailed
Systems
Design
39,000
10,800
14,400
53 ,400
10,800
64,200
Program
Specifications
15,800
3,600
15,800
3,600
19,400
Program
Development
21,800
6,000
7,600
200
29,600
6,000
35,600
Documentation
Preparation
19,600
5,600
2,400
22,000
5,600
27 ,600
System
Test
19,600
5,600
12,400
200
200
32,400
5,600
38,000
Total
Development
Costs
115,800
31,600
20,000
200
17,200
153,200
31,600
184,800
m
X
X
ro
H
<
cn
-------
ADMINISTRATIVE AGENCY
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE I I-Smal 1
Cost
Elements
Peisonnel Resources
Conipulei Resources
Supplies/
Other
T otals
Conuaeloi
EPA
Computer
Suppait
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out of Pocket
Expenses
Opportunity
Costs
total
Implementation
Data
Conveision
11,400
200
100
900
1,500
100
200
200
13,40C
1,200
14,600
3,200
1 raining
2. IOC
100
100
400
500
2 , 60C
600
Prototype
Operation
3,200
500
600
1,700
5,500
100
800
200
9,80C
2,800
12,600
Total
Implementation
lfi,7nn
C
c
a
ftOO
3.000
7 rOOO
?00
1 .000
900
25.80C
4.600
30.400
Fiist Yoar
Operating
Data Entry &
Update
400
1,000
200
500
1,800
900
1,300
100
4, 50C
1,700
6,200
Processing &
Reporting
2-r^OG-
-2.,300
1,200
12-^200
7, 300
Z,.6Q.O-
aao-
L,.6Q0_
LQCL
100
LOl,JLQI
IOC
17,000
8,500
_2X,-1QQ-
8,600
Management
& Analytic
System
Maintenance
Total First
Year
40C
3, 500
3,700
20,000
9,400
1,700
2,900
300
14,70C
27,200
41,900
Lile Cycle
Operating
Data Entry ft
Update
2 .200
5, 5no
12.,JZ£10
6 ,700
_2.,-8QQ
67,400
L9M,
42,000
5.,HQ£L
4 ,400
7.200
600
24.90C
9,400
34,300
Processing &
Reporting
13,800
8,800
600
55,80C
93,900
149,700
Management
& Analysis
System
Maintenance
40,300
600
60C
47,000
47,GOO
Total
Lile Cycle
18.900
20,100
21,200
113,500
58,900
9,600
17,000
2 ,700
107,100
154,800
261,900
-------
ADMINISTRATIVE AGENCY roT1...Tro
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE TT - Large
Cost
Elements
Peisonuel Reiouicei
Computet Resouices
Supptiei/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Cltlicil
EPA
Professional
Processing
Storage
Communication
Out of Pocket
Expenses
Oppoitunity
Costs
Total
Implementation
Oata
Conversion
423,000
1,000
5,500
900
2,600
300
400
4,500
4 30,800
7, 400
438,200
Training
2.100
100
200
600
200
600
2, 700
900
3,600
18,500
Prototype
Operation
3,200
500
900
2, 700
9,700
800
500
14,400
4,100
Total
Implementation
428,300
l finn
ft fion
4, ?nn
n ?,^nn
snn
i , ?nn
5 r 600
447.900
12.400
460.300
First Yeai
Operating
Data Entry &
Update
2,100
1,000
74 .200
700
4,900
1,500
1, 300
200
10,000
75,900
85,900
Procaising ft
Reporting
2,500
_23j000
1.600
159,500_
9 .800
-16,-500
_l-r500-
1.,600-
200
19,800
-185.,-OQO
11,400
.2Q4.,.800
11,500
Management
& Analysis
100
100
System
Maintenance
Total First
Year
2.100
3.500
98.800
1.70,000
21,400
3,000
2 ,900
500
29,900
272,300
302,200
Life Cycle
Operating
Data Entry &
Update
_11,600
5,^500
13,800
¦410 ,000
127,100
3,900_
381,300
-2-7-, -1-00
91,200
-8,-300-
8, 300
-7-,-200
8,800
1-,-1-QO-
1,100
SS-,-300
109,400
4-19 ,-400
1.,022 , 20C
_4-74-,-700
1,1 31, 6(
Processing ft
nepottlng
Management
& Analysis
8,800
54,200
...
600
600
63,000
63,600
System
Maintenance
Total
Life Cycle
439,900
209,000
552,500
943,600
130,600
17,100
17,200
8,400
613,200
1,517,OQ
0 2,130,
-------
EPA HEADQUARTERS
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
alternative II - EPA - Fixed Cost
Cost
Elements
Personnel Resouices
Computet Resouices
Supplies/
Other
Totals
Contiactor
EPA
Computer
Support
EPA
Clerical
EPA
Piolessiooal
Pf settling
Storage
Communication
Out o! Pocket
Expenses
Opportunity
Casts
Total
Implementation
Data
Conversion
Training
Prototype
Operatioo
3,200
500
600
1,700
5,500
100
800
200
9,800
2 ,80C
12,600
Total
Implementation
3.200
500
600
1.700
5.500
100
800
200
9,800
2 , 80C
12,600
First Year
Operating
OaU Entry ft
Update
Processing &
Repotting
Management
& Analysis
System
Maintenance
17.600
4.400
16.400
5 .000
21.40C
22,00C
4 3,400
Total First
Yeai
17,600
4,400
16,400
5,000
21,40C
22,00C
4 3,400
Life Cycle
Operating
Oata Entry &
Update
Processing &
Repotting
Management
& Analysis
27.600
121.60C
Syslein
Maintenance
97.300
24.300
90.600
118.20C
2 39.800
Total
Lite Cyde
3,200
97,800
600
26,000
96,100
100
28,400
200
128,000
124,400
252,400
-------
Compliance History Reports - generated monthly or
quarterly for states, and quarterly for EPA
Headquarters and regions
Violations Report - generated monthly for state
program compliance and enforcement personnel.
Data Entry Volumes - The following are the data entry
volumes assumed fo"r Alternative III:
Coding/Keypunching of Permittee Information -
Same as Alternative II
Coding/Keypunching of Compliance Information - It
was assumed that 700 records will be updated,
deleted or added to automated files annually in
a small volume entity, and 3,500 records in a large
volume entity.
Training - Same as Alternative II.
Alternative System Cost Estimates - Alternative III system
development costs and implementation, operation and life
cycle costs are presented in Exhibits IV-8, IV-9a, IV-9b,
and IV-9c.
(4) UIC Alternative IV Conceptual Design
Discussed below are the specific assumptions and cost
analyses for the UIC Alternative IV (Decision Support System)
conceptual design.
Specific Assumptions - The following are the assumptions
particular to the development of Alternative IV costing.
Number of Computer Programs - The following are the
major categories and number of programs required:
1 Edit/Update Module
1 Compliance Module
1 Enforcement Action Module
1 Program Analysis Module
2 Report Generators
1 Federal Data Extract Program
Required Files - All files listed under Alternative
III will be used by this alternative. In addition the
following file will also be used:
IV-15
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM DESIGN AND DEVELOPMENT
ALTERNATIVE
DESIGN ALTERNATIVE III - COMPLIANCE/TRACKING SYSTEM
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol Pocket
Expenses
Opportunity
Costs
Totat
Detailed
Systems
Design
78,000
13,600
14,400
92,400
13,600
106,000
Program
Specifications
30,400
5,600
¦
30,400
5 ,600
36,000
Program
Development
43,600
9,600
10,000
200
53,800
9,600
63,400
Documentation
Preparation
39,000
10,800
2,800
41,800
10,800
52,600
System
Test
39,000
8,800
16,800
200
200
56,200
8 ,800
65,000
Total
Development
Costs
230,000
48,400
26,800
200
17,600
274,600
48,400
323,000
m
x
I
OT
H
<
00
-------
ADMINISTRATIVE AGENCY
'.COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE TTT-Smal1
Cost
Elements
Personnel Hesouiccs
Coinputei Reiomces
Supplies/
Other
Totals
Contractor
EPA
Compater
Support
EPA
Clerical
EPA
Piofniional
Processing
Stoiage
Communication
Out ol Pocket
Expenses
Opportunity
Costs
Total
Implementation
Daia
Conversion
11,400
200
100
900
1,500
100
200
200
13,400
1,200
900
14,600
4. IOC
Training
2.500
200
200
500
700
3.200
Prototype
Operatioo
6,400
1,000
1,200
3,400
8, 300
200
1,600
200
16,700
5,600
22,300
Total
Implementation
20,300
1,400
1,500
4,800
9,800
300
1,800
1,100
33,300
7,700
41,000
First Year
Operating
Data Entry ft
Update
1, 300
1,000
900
1.400
3.500
900
1, 300
200
7,200
3,_300
12,800
10,50C
Processing ft
Reporting
3,800
1,800
7,200
12,800
1, 200
2,400
200
16,600
29,40C
Management
& Analysis
1,600
7,500
200
200
9,100
9, 30C
System
Maintenance
Total First
year
1. 300
4,800
4,300
16,100
16,300
2,100
3, 700
600
24,000
25,200
49,20C
Life Cycle
Operating
Data Entry &
Update
7,200
5,500
21.000
-5.^000-
9.900
7.7°o
39.800
19-,-300
70.700
_5-,.000-
6 .600
7-,.200
13,300
1_,.10Q.
1.100
_39_, 800
91,700
18.. 200
70,700
5.8.,.QOC
162 ,400
51,300
Processing &
Reporting
Management
& Analysis
Syitem
Maintenance
8,800
41,400
1,100
1,100
50,200
Tola!
Lile Cycle
27.500
27.900
25,200
93,700
99,800
11.900
22,300
4 ,400
165,900
146,800
312,700
-------
ADMINISTRATIVE AGENCY COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE III - Large
Cost
Elements
Personnel Resource!
Cnmputer Resoutces
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Sloiage
Communication
Out o! Pocket
Expenses
Opportunity
Costs
Total
Implementation
Oita
Conversion
'42 3,000
1,000
5,500
900
2 , 60C
300
400
4,500
4 30,800
7,400
4 38,200
Training
2,500
200
20C
800
800
3, 300
1,200
4,500
Prototype
Operation
6,400
1,000
1,80C
5,400
11,90C
400
1,600
500
20,800
8,200
29,000
Total
Implementation
431 .900
2.200
7.50C
7.100
14.50C
700
2.000
5.800
454.900
16 .800
471.700
Fiist Year
Opeiating
Data Entry ft
Update
28,100
1,000
21,600
2, 300
9,80C
1,500
1, 300
300
41,000
24,900
65,900
Processings
Reporting
3, ROO
16_,.5QC
2,000
_6_2-,-800_
10,200
24,_8QC
2.,3Q0_
2.^400.
^nn
29.,.800
200
_83.,.10Q_
12,200
112_,_9O0.
12,400
Management
& Analysis
200
System
Maintenance
Tots! First
Year
28,100
4,800
40,100
75,300
34,600
3,800
3, 700
800
71,000
120,200
191,200
Life Cycle
Operating
Data Entry &
Update
155,300
5.,_5lQO
21,000
119,400
91,20C
12,700
5A.2QD
_a,-3Q£L
12,700
7_,_2Q_Q.
13,300
l.,JZQQ
1,700
_22&,700
164,700
137. ..600
4 59,200
364,100.
623,900
Processing ft
Reporting
347,000
137,000
Management
& Analysis
System
Maintenance
11,100
56,400
1,100
1,100
67,500
68,600
Total
Lite Cydo
587,200
28,700
229, 700
423,200
191,20C
21,700
22,500
10,300
847,400
681,100
1,528.5f
-------
EPA HEADQUARTERS COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE TTT - EPA - Fixed Coat
Cost
Elements
Personnel Resources
Computer Resouices
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Prolessional
Processing
Storage
Communication
Supplies/
Other
Out ol Pocket
Eipenses
Opportunity
Costs
Total
Date
Conversion
Implementation
Training
Prototype
Operation
6,400
1,000
1,200
3,400
8, 300
20C
1,600
200
16,700
5,600
22,30C
Total
Implementation
6.400
1.000
1.200
3,400
8, 300
20C
1,600
200
16,700
5,600
22,30C
Date Entry &
Update
Processing &
Reporting
First Year
Operating
Management
& Analysis
System
Maintenance
17.600
4 ,400
24,600
5,000
29,600
22,00C
51,60C
Tuld First
Year
17.600
4 .400
24,60C
5,000
29,600
22,00C
51,60(
Data Entry &
Update
Processing &
Reporting
Life Cycle
Operating
Management
& Analysis
System
Maintenance
97,300
24,30C
135,90C
27,600
163,600
121,60C
285,20(
Total
Life Cycle
6,400
98.300
1,200
27.700
144.200
200
29,200
180,300
127,200
307,500
-------
Enforcement Action File.
Reports Generated - All reports listed under
Alternative III will be used by this alternative. In
addition the following reports will be generated:
Program Analyses Reports generated quarterly for
State program administrations and regional staffs
Program Status Report generated quarterly for
State program administrations and regional
program monitors
Enforcement Action & Status Summary Reports
generated monthly or quarterly for State
enforcement staffs and regional program monitors.
Data Entry and Update - The data entry volumes for this
alternative increase marginally over that of
Alternative III. The increase can be traced to the
number of major enforcement actions. These are 2 for
a small volume entity and 50 for a large volume entity,
respectively.
Training - Same as Alternative III, except that both
professional training and ADP training sessions will
be expanded.
Alternative IV System Cost Estimates - Alternative IV system
design and development costs, and implementation, operations,
and life cycle costs are presented in Exhibit IV-10, IV-lla,
IV-llb, and IV-llc.
(5) UIC Alternative Cost Summary
Exhibits IV-12, IV-13, and IV-14 represent first-level
analysis summaries of the detailed costs developed for each
alternative. Exhibit IV-12, EPA Headquarters Life Cycle Cost
Summary, aggregates costs from two exhibits from each alternative.
The design and development row of this exhibit carries forward
the total out-of-pocket and opportunity costs developed in each
alternative's system design and development matrix. The
implementation and operations rows of this exhibit carry forward
the costs which were developed in the EPA Headquarters
implementation and .operations exhibits for each alternative. The
life cycle row is therefore the sum of design and development,
implementation, and operations.
Exhibit IV-13, Administering Agency Life Cycle Summary,
aggregates costs from the detailed implementation and operations
exhibit (administering agency) developed for both a large and a
small administering agency. Out-of-pocket costs and opportunity
IV-1 6
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM DESIGN AND DEVELOPMENT
ALTERNATIVE
DESIGN ALTERNATIVE IV - DECISION SUPPORT SYSTEM
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol Pocket
Expenses
Opportunity
Costs
Total
Detailed
Systems
Design
107,400
19,200
14,400
121,800
19,200
141,000
Program
Specifications
41,400
8,400
41,400
8,400
49,800
Piogram
Development
60,200
14,400
17,600
200
78,000
14 ,400
92,400
Documentation
Preparation
53,800
17,200
4,000
57,800
17,200
75,000
System
Test
53,800
14,000
29,400
400
200
83,800
14,000
97,800
Total
Development
Costs
316,600
73,200
47,000
400
18,800
382,800
73,200
456,000
m
X
X
CD
-------
ADMINISTRATIVE AGENCY
i COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE TV-Small
Cost
Elements
Peisonnel Resource!
Computet Resniuces
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol PocVet
E Kpensn
Opportunity
Cosh
Total
Implementation
Data
Conversion
11,400
200
?no
100
900
1, 500
100
200
200
13,400
1,200
14,60C
6, 50C
Training
4 j
300
aoo
1.000
5,200
1, 300
Prototype
Operation
6.400
1 .000
1.200
3,400
9, 300
200
1,600
200
17,700
5,600
2 3,30C
Total
Implementation
22,000
1,400
1,600
5,100
10,800
300
1,800
1,400
36,300
8,100
44,40C
First Year
Operating
Data Entry &
Update
1,300
_1,000
4,700
900
1,400
3, 500
900
1, 300
200
7,200
3,300
10,50C
Processing &
Reporting
1,600
7,400
14,200
1,500
3,000
200
18,900
13,700
32,60C
Management
& Analysis
2,000
8.000
200
200
10,000
10,20C
System
Maintenance
TotU First
Year
i j inn
7nn
4 .500
16.800
17.700
2.400
4, 300
600
26,300
27,000
53,330
Life Cycle
Operating
Data Entry &
Update
7, 200
5, 500
5,000
7,700
19,300
5,000
7, 200
1,100
39,800
18,20C
58,00C
Processing &
Reporting
-26-,-000-
_ 8,800
11 -100
_40f900
1 1*
! P
a_3O0L
_l£,£fl£>
1.100
104.500
75,70C
55,30C
180,200
Management
& Analysis
1,100
1.10C
56,40(
System
Maintenance
Total
Life Cycle
29.200
32,900
26,500
97,900
108.600
13,600
25,600
4,700
181,700
157,300
339,000
-------
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
alternative IV - Large
Cost
Elements
Peisonnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol Packet
E xpenm
Opportunity
Costs
Tola)
Implementation
Data
Conversion
423,000
1,000
5,500
900
2,60f
300
400
4,500
430,800
7, 40C
438,200
Training
4,200
200
400
1,200
1,200
5,400
1,80C
7, 200
Prototype
Operation
6,400
1,00C
1,800
5,400
12,90C
400
1,600
500
21,800
8, 20C
30,000
Total
Implementation
433. son
7 . ?or
7.700
7.500
1 5 .50C
700
2 .000
6. 200
458,OOC
17,40C
475,400
Fiist Year
Operating
Data Entry &
Update
28,300
1,00C
22,000
2, 300
9 ,80C
1,500
1,300
300
41,20C
25,30C
66,500
Processing ft
Reporting
4,6or
17,300
60,200
10,500
35.,60(
2,^0D_
3.,_QQQ.
400
41.80C
82.IOC
123.900
Management
& Analysis
2,500
200
20C
13,OOC
13,200
System
Maintenance
Tola] First
Year
28.300
5,60C
41,800
73,000
45,40C
4, 300
4 , 300
900
83,20C
120,40C
20 3,600
Life Cycle
Operating
Oata Entiy &
Update
Processing &
Reporting
1-56t400-
5,-50C
25,40C
121^,600
95,600
-1-2.^00-
332,600
54-,2Q£
196.70C
8,300-
15 .500
7-,-2Q£l
16.600
L^ZQO
2, 200
_22.7_,_80£
231,OOC
139,800
453,600
367,500
684,600
Management
& Analysis
13,800
58,000
1,100
1,10C
71,80(
72,900
System
Maintenance
Total
Life Cycle
590,000
33,100
238,700
410,800
266,400
24,500
25,800
11,200
917,900
682,600j
L ,600,50
-------
EPA HEADQUARTERS
COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPEHATIONS
ALTEHNATIVE IV - EPA - FIXED COST
Con
Elemtfiili
Peisuimcl llmuuicut
Cumjiialcr Nciuuices
1 ulals
Cmliacliw
EPA
Compute*
Supiiuil
(PA
Clriical
EPA
Piuleitional
f weening
Storage
CoKM»iiiiicaiii/(i
Supplied
Otliei
Out al Packet
I ipCllUI
Optioilunily
Coil*
foul
UaU
Conveition
Imjiluiiiefitation
Training
Piataiype
Opeulion
6,400
1,200
1,200
3,900
9,300
200
1,600
200
17,700
6, 300
24,00C
Told
luipUuteulitMQ
6,400
1,200
1,200
3,900
9, 300
200
1,600
200
17,700
6, 300
24,00C
Dull f iiliy &
Update
First Yeai
Opcialiug
Ptoceuiag ft
llc^iuiling
Mauajjemenl
ft Analyth
¦ - - ¦
---
-
Syileui
Maiulenanct
20,200
5,100
30,300
5,000
35,300
25,300
60,600
Total finl
Veai
20,200
5,100
30,300
5,000
35,300
25,300
60,60C
Uala Cully &
1/pditlr
Piaccuing &
fleportiuf
Lite Cycle
0|tei alitiQ
Management
ft AuaJyiil
Syilem
M^tnleiiauco
111,600
28,200
167,400
27,600
195,000
139,800
3 34,80C
Total
lile Cycle
6,400
112,800
1,200
32,100
176,700
200
29,200
200
212,700
146,100
358,80C
-------
EPA HEADQUARTERS LIFE CYCLE COST SUMMARY
EPA HQ LIFE CYCLE COST SUMMARY
(DOLLARS IN THOUSANDS)
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 4
Out
of Pocket
Oppor-
tunity
Total
Out
of Pocket
Oppor-
tunity
Total
Out
of Puckct
Oppor-
tunity
Total
Out
of Pocket
Oppor-
tunity
Total
Design &
Development
48.5
5.5
54.0
153.2
31.6
184.8
274.6
48.4
323.0.
382.8
73.2
456.0
Implementation
-
-
-¦
9.8
2.8
12.6
16.7
5.6
22.3
17.7
6. 3
24.0
Operation
.6
3.3
3.9
118.2
121.6
2 39.8
163.6
121.6
285. 2
195.0
139. 8
334.8
Lite Cycle
49.1
8.8
57.9
281.2
156.0
437.2
454.9
175.6
630.5
595.5
219. 3
814.8
m
X
X
55
<
N>
-------
ADMINISTRATIVE AGENCY
LIFE CYCLE IMPLEMENTATION & OPERATIONS
COST SUMMARY
(DOLLARS IN THOUSANDS)
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 4
Out
of Pocket
Oppor-
tiniity
Total
Out
ol Pocket
Oppor-
tunity
Total
Out
of Pocket
Oppor-
tunity
Total
Out
ol Pocket
Oppor-
tunity
Total
SMALL
ADMINISTRATIVE AGENCY
Implementation
8.7
23.2
31.9
.25.8
4.6
30.4
33.3
7.7
41.0
36. 3
8.1
44.4
Operation
8.4
195.7
204.1
81.3
150. 2
231.5
132.6
139.1
271.7
145.4
149. 2
294.6
Life Cycle
17. 1
218.9
236.0
107.1
154.8
261.9
165.9
146.8
321.7
181.7
157. 3
339.0
LARGE
ADMINISTRATIVE AGENCY
linplcmciitation
15.0
319.0
334.0
447.9
12.4
460.3
454.9
16.8
471.7
458.0
17.4
475.4
Operation
28.9
1688.0
1716.9
165.3
1504.6
1669.9
392.5
664. 3
1056.8
459.9
665.2
1125.1
Lile Cycle
43.9
2007.0
2050.9
613.2
1517.0
2130.2
847. 4
681.1
1528.5
917.9
682.6
1600.5
-------
costs for each are carried forward to the appropriate cells in
the implementation and operation rows for each alternative. The
life cycle represents the sum of implementation and operations
costs.
Exhibit IV-14 represents aggregate life cycle costs which
will be incurred for a large administering agency if it incurred
all system associated costs. Out-of-pocket and opportunity costs
for the system design and development row are brought forward
from the system design and development exhibit of each
alternative. With respect to the EPA Headquarters implementation
and operation row, the total out-of-pocket and opportunity costs
are brought forward from each alternative exhibit. The same
procedures will also apply for the administering agency
implementation and operations row. This basically presents the
costs to EPA if only one State were implemented. The lowest cost
is for the manual approach, which indicates that development of
an independent UIC Information System would not be justified for
an individual State. However, implementation of Alternative III
by EPA can almost be cost justified for one large State
implementation. Assuming more than one such State will utilize
the system, the cost savings are potentially significant.
The following paragraphs provide an analysis of these summaries.
System Design and Development Costs - System design and
development costs are highest in Alternative IV. This is
due to the maximum automated capability and the level of
complexity built into the system. These characteristics are
reflected in the significant increase in development time
incurred by both contractor and EPA personnel. Additionally,
computer processing costs are greatly increased in testing
Alternative IV. The lowest design and development costs are
shown in Alternative I, the manual system. This cost reflects
the development and documentation of a series of manual
procedures for an EPA Region which is administering the
program. It consists of EPA personnel resources, both
professional and clerical, expended in the procedures
development process. The increasing automated capabilities
of Alternatives II and III are indicated by the increased
cost of development. The most significant increment among
the automated alternatives occurs between II and III. This
is due to a significant increase in automated system
capability, going from a file maintenance, report generator
capability to that same capability with the addition of a
compliance oriented automated process which develops and
tracks schedules and screens monitoring reports. Although
development costs increase from alternative to alternative,
the automated capability of each additional concept is
significantly increased as well.
IV-17
-------
LIFE CYCLE COST PROJECTIONS
(DOLLARS IN THOUSANDS)
LARGE STATE
Cul
COIII|10I1FI1|1
ALTEHNATIVEI
ALTEIINATIVE 2
ALTEIINATIVE 3
ALTERNATIVE 4
OulolPocktl
Eapenm
Opposlunily
Cotli
Toul
Out ol Pocket
Ea|)cmci
Otijioiluiilty
Com
lain)
Out ol Packet
E Kptmai
0|>|tof Itniity
Custi
Total
Out ol Puckct
Eipeutes
OpjHiitunily
Ciisli
Total
Syiiim Uttlgit ft O«v«topin*nl
48.5
5.5
54. n
153.2
31 .ft
ifi/i. n
274.fi
4f!_4
323.0
382.8
73.2
Tifl.R
CPA lin|ilitn«ii«iloi
ind
.6
3.3
3.9
128.0
1517.0
252 .4
180.3
127.2
1528.5
212.7
917.9
146.1
682.6
Ailtnlnh1i«lton Agtucy
ImptaineiiKiloH ami Opatilloni
43.9
2007.0
2050.9
613.2
2130.2
047.4
681.1
1600.5
LIFE CYCIE
93.0
2015.8
2108.0
894.4
1673.0
2567.4
1302.3
856.7
2159.0
1513.4
901.9
2415.3
-------
System Implementation Cost - Two sets of implementation
costs were developed for each alternative system concept.
Costs were developed for a large volume administering agency
and a small volume administering agency. This approach was
chosen due to the mix of designated States in terms of the
number of wells in each State's inventory. Life cycle costs
assume a 5-year system life cycle. The costs for
implementing the automated alternatives in both the large
and small volume environments increase incrementally from
Alternative II through Alternative IV. This same pattern
is followed in the transition from the manual system
(Alternative I) to the basic automated system (Alternative
II) in a large volume environment. This pattern is not the
case in the small volume environment, although the relative
difference for implementation between Alternative I and II
is negligible. What is of interest between Alternatives I
and II is the significant increase in opportunity costs.
Out-of-pocket costs increased because of the data conversion
process which will be performed by a vendor. Additionally,
there is a dramatic decrease in the opportunity costs between
Alternatives I and II. This is attributed to the significant
manual effort required in prototype operations to initiate
the inventory files, set up the filing controls, and
additional manual effort which utilizes a considerable
amount of time. When the files are automated in Alternative
II, this manual cost is reduced to a minimum. Costs between
Alternatives II, III and IV do not vary significantly for a
small volume, although the automation capability increases
significantly between II and III. The capability/cost
increase ratio shows some significant cost increments in a
large volume environment, specifically between II and III.
With respect to EPA Headquarters implementation costs, these
are only incurred in the automated alternatives. In the
manual systems alternative, we have made the assumption that
implementation costs will be included in the States and
fixed costs would be minimal. On the other hand, EPA
Headquarters will incur implementation costs in the
automated alternatives due to the support which will be
provided to the States in the form of a prototype operation.
Increases in implementation costs in the transition from
Alternative II to Alternative IV are attributable to the
fact that the increasing level of automation inherent in
the transition wi 11 accrue increased incremental costs. This
pattern applies as well to the components of the
implementation totals -- out-of-pocket cost and opportunity
costs.
System Operating Costs - Operating costs exhibit two general
patterns which are a function of the volume environment. In
the small volume environment, operating costs increase from
alternative to alternative, while in the large volume
IV-18
-------
environment, these costs decrease (with the exception of
Alternative IV where there is a small increase). A further
analysis into the components of operating costs is a key
factor in the explanation of these patterns. Out-of-pocket
costs for both the large and small environment show increases
as the level of automation increases. With increasing levels
of automation, machine costs are the determining factors.
On the other hand, opportunity costs for both the large and
small volume environment decrease as the levels of
automation increase (with the exception of Alternative IV).
Further analysis of opportunity costs reveals a
significantly larger percentage decrease in the transition
from Alternative II to Alternative III for the large volume
environment as opposed to the small volume environment. The
decrease in itself for both environments can be explained
by the fact that screening of the monitoring reports becomes
automated in Alternative III. The percentage decrease is
explained by volume (4000 reports in the small environment;
140,000 report's in the large environment). As a final point
in this analysis, the absolute magnitude of opportuinity
cost decreases far outweigh the dollar increases in out-of-
pocket costs in the large environment, thus resulting in
decreasing total operating costs. In the small environment,
this is not the case. The small magnitude of decrease in
opportunity costs does not counterbalance or exceed the
magnitude increase in out-of-pocket expenses. As a result,
total operating costs rise with increasing levels of
automation in the small environment.
With respect to EPA Headquarters operating cost, we can see
that these costs increase as the level of automation
increases. This is entirely a function of systems
maintenance. In the manual alternative, system maintenance
will be no more than periodic documentation and procedures
revisions performed centrally at EPA Headquarters. In the
automated alternative, operating costs rise more
significantly due to the scope and complexity of the systems
maintenance to be performed.
6. EFFECTIVENESS ANALYSIS OF ALTERNATIVES
In the analysis described in Chapter III, each alternative system
concept was evaluated against the evaluation criteria defined in
Chapter II. The pattern which emerged was one of increasing capability
in each alternative, a decreasing requirement for labor intensive
functions, and increasing system complexity requiring potentially some
modification to typical skill mixes. This effectiveness evaluation
can be translated into impacts on the administration, monitoring, and
program management functions. The incremental impact of each of the
alternative system concepts is illustrated in Exhibit IV-15. In the
following paragraphs, the effectiveness of the alternatives is briefly
discussed, with regard to each of the three participating groups,
IV-19
-------
UIC SYSTEM ALTERNATIVE IMPACT ANALYSIS
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 4
EPA
Headquarters
Hard Copy Annual
Reports
Limited Response
To Information
Requests
Improved Response
To Information Requests
Substantial Part of Annual
Reports Received in Machine
Readable Form
Effective Response to
Information Requests
EPA
Region
Program
Monitor
¦ Hard Copy Summary
Reports Received
Limited Response
To Information Requests
s Inventory Maintained
from Hard Copy
Effective Response
To Information Requests-
Inventory, Permits
¦ Limited Response To
Requests for Enforcement
Information
Inventory Maintained from
Machine Readable Reports
Effective Response
To Information Requests
Machine Readable
Reports Received
e Inventory Maintained from
Machine Readable Reports
¦ Facilitated
Program Review
Region
or
State
Level
Program
Administration
Standardized Procedures
for Handling UIC Data
Heavy Manpower Resource
Requirement to Manually
Record Data
¦ Labor Intensive Reporting
Effective Permit Tracking
Effective Response to Requests
Regarding Inventory Data
Labor Intensive Self-
Monitoring Report Record
Keeping
Compliance Monitoring Limited
To Available Manpower Resources
Labor Intensive Compliance
Reporting
t Effective Operations
Tracking & Monitoring
Effective Response to
Information Requests
* Optimum Resource
Allocation
Extend Enforcement
Tracking Support
Facilitated Program
Effectiveness Analysis
-------
Region/State Administrators, Regional Monitor, and EPA Headquarters
Program Managers. In addition, an analysis of alternative system
implementation approaches is provided.
(1) Regional/State Administrators
This group of participants is comprised of States which have
accepted primacy and Regions which are administering the program
for non-primacy States. The functions of this group encompass
the day-to-day operations for permit issuance, permit and
compliance tracking, self-monitoring reports processing, and
enforcement scheduling and tracking.
Alternative I is a totally manual system comprised of logging
and control procedures, report development, and operations
management. Implementation of the system would establish
common procedures which would facilitate communication with
the monitoring function, and assure that all required data
are maintained. However, record keeping and reporting are
labor intensive operations under this alternative. For
environments which generate data of any great volume the
system will require a large labor force and will suffer the
inaccuracies which typically result from manual data
handling. The system may be effective if a State which
manages the UIC program via multiple agencies has a
sufficiently small UIC activity that work distributed among
the agencies can be handled manually.
Alternative II provides for automated permit tracking and
an automated operations inventory. This alternative
effectively reduces workload by automating permit
application processing. Effective response to information
requests regarding either the inventory or permit status is
provided via the automated system. However, a major manual
workload in the form of self-monitoring reports received
periodically still remains. As a result, the compliance
monitoring function is significantly limited. Preparation
of summary reports is facilitated by the automated inventory
and permit files, but data on compliance activities must
still be compiled manually.
Alternative III provides for automation of all the permit,
inventory, and compliance operations. The manual workload
is significantly decreased as a result of automated
processing of permit applications and self-monitoring
reports. Effective response to information requests can be
provided, since all data is accessible by computer. A
somewhat different skill mix may be required if the State
or Region does not already employ systems staff. However,
this alternative should result in the elimination of major
manual operations which can be effectively accomplished via
automation.
IV-20
-------
Alternative IV provides the same automated capability as
A1ternative TTl, but includes the additional automated
functions of enforcement tracking and program effectiveness
analysis. The enforcement tracking function provides an
advanced capability to assist in determining required
enforcement actions, and to track the actions from initiation
to closeout. The program effectiveness capability analyzes
program performance in terms of previously determined
objectives. Both of these capabilities are advanced program
management and require some sophistication on the part of
the user. The capability could contribute to program
effectiveness but does represent a possible new staffing
requi rement.
(2) EPA Regional Monitors
The EPA Regional monitoring function is directed at ensuring
the effectiveness of the programs conducted by delegated States.
This function consists of receipt and review of quarterly reports
submitted by the delegated States, periodic on-site review of
State operations, and response to requests for information
regarding the UIC program.
Alternative I, as- a manual system, will result in hard copy
periodic reports submitted to the Region. The Region will
have to enter the inventory data from hard copy. The manual
system will have the effect of limiting the response to
information requests asked of the Region and forwarded to
the administering State. Confidence in detailed data will
be low due to anticipated error rates in manual data
hand 1ing.
Alternative II, which automates permit tracking and
inventory maintenance for the administration function,
provides some advantages to the monitoring Region as well.
The inventory can be updated from machine readable media.
The response to requests for information concerning permit
status will be improved. However, periodic reports submitted
to EPA regarding State activities will be hard copy. Also,
manual access to compliance activity records by the
administrating State/Region will limit responsiveness to
compliance information requests.
Alternative III, which includes automated compliance
tracking and self-monitoring reports processing, will
provide advantages to the monitoring Region. As in
Alternative II, inventory maintenance will be facilitated
via machine readable input. Response to information requests
will be facilitated due to mostly automated records. In
addition, annual reports to the monitoring Region can be
provided in mostly machine readable format to facilitate
entry into the Federal Reporting System.
IV-21
-------
Alternative IV encompasses all capabilities of Alternative
II with the addition of automated enforcement tracking
support, and facilitated program effectiveness analysis.
These analytical capabilities should facilitate program
review conducted periodically at the administering State or
Reg ion.
(3) EPA Headquarters Program Management
The program management function is concerned with assuring
the effectiveness of the nationwide UIC program. In addition,
EPA Headquarters is the focal point of information requests from
the Congress and the public. To support this function, a Federal
Reporting System will be developed to contain an inventory of
all operations and summaries of UIC activities. The source for
this data will be the annual and quarterly reports submitted by
the States or administering Regions.
The system concept employed by the administering States or
Regions affects the Program Management function in two ways:
By the ease with which data is reported, because it affects
timeliness and accuracy
By the assistance it provides to the State/Region, because
effective support can improve program administration.
In this sense, each of the alternatives provides some advantage
to the Headquarters function. This advantage is essentially
parallel to the advantages provided to the Administering State
or Region.
Alternative I, as a manual capability, provides the minimal
advantage of standardizing record keeping and reporting.
Alternatives II and III provide partial automated support
to daily operations. As~such, they represent effective tools
for program administration and information reporting.
Alternative IV provides the same daily operations support
as Alternative III with the addition of advanced analytical
capabilities. These analytical functions provide a useful
tool for management analysis which, if utilized by the
administering State or Region, helps to assure EPA
Headquarters of effective program management at the program
administration level.
7. UIC SYSTEM CONCEPT RECOMMENDATION
An analysis of the costs and benefits of the alternatives leads
to the recommendation for Alternative III. This recommendation
represents the maximum automated capability which can be achieved
IV-22
-------
through a straightforward system which does not require advanced
technical skills to operate.
Based upon the cost estimates, we believe that, if EPA is to
administer at least one large State, the additional cost for
implementation, design, and development of Alternative III over
Alternative I is justified in terms of life cycle cost. This primarily
reflects the substantial decrease in operating cost due to the
automated screening and maintenance of self-monitoring reports in
Alternative III. Alternative IV provides the same capability but is
always more costly than Alternative III. Alternative IV also provides
management analysis and support capability; however, this added
complexity does not appear justified in the near term.
On the assumption that more than one large State, or Region with
a large State, will utilize the UIC Information System, we recommended
implementation of Alternative III. This is based upon:
Alternative III offers the lowest implementation and
operation cost to an Administrative Agency for all but the
smallest agencies
Implementation in only one large Administrative Agency
almost cost justifies EPA's fixed costs
Alternative III minimizes the manual reporting burden on
the Administrative Agency
The added complexity of Alternative IV does not meet the
evaluation criteria for minimizing required levels of
technical support
Alterative III provides significantly more management
reporting and analysis capability than Alternative II, as
well as a cost advantage.
In summary, Alternative III offers significant advantages to EPA both
in terms of cost and effectiveness.
8. ALTERNATIVE SYSTEM IMPLEMENTATION APPROACHES
The decision with regard to centralization or distribution is
the question whether EPA will develop a system and implement it in
individual states (distribution) or whether the Agency will develop
a system for use by the Regions which the States may access if they
so desire (centralization). There are considerable costs involved in
this decision, but there afe other considerations as well. The impacts
of the alternatives on both EPA Headquarters and the State are
illustrated in Exhibit IV-16. These impacts are discussed in the
paragraphs below, and are then followed by a cost analysis.
IV-23
-------
UIC INFORMATION SYSTEM
IMPLEMENTATION ALTERNATIVES IMPACT ANALYSIS
CENTRAL
DISTRIBUTED
EPA
Headquarters
e Facilitates Change and Enhancement
as Program Evolves
Easier System Maintenance
Encourages Common System Use
Heavier Processing Workload
Major Coordination Requirement
Requires Development of Transportable
Software-Technologically Demanding
May Encourage Primacy
May Encourage Standard Systems
State
e Limited to Standard Processing
Cycles
e System Maintenance is More Timely
Not Necessary to Acquire an Automated
Capability
State Particular Enhancements Limited
e Processing Cycles at State Discretion
State Responsible for Own System
Maintenance and Operation
Automated Capability Required
-------
(1) Centralized Implementation Alternative
The centralized implementation alternative is simply a
matter of extending the configuration developed for the Regions
to include States who wish to use the EPA UIC information systems.
In this case the software and data bases are maintained at a
central EPA facility. Access to appropriate data bases by the
regions and States is via terminals and remote printers. The
security of an individual State's data can be maintained via
limitation of access to only that State. The system will access
the Federal Reporting System directly.
The impact of the alternative on EPA Headquarters is in
terms of facilitating system management and encouraging the use
of a common system. Maintenance functions will be performed on
one set of software. Similarly, system modifications will also
be performed, after agreement by all users, on one set of software.
As a consequence, system changes can be accomplished more
efficiently. The Headquarters facility will experience a heavier
processing workload. However, the centralized implementation may
encourage use of a single system and thereby simplify EPA
monitoring functions.
The impact on the State is one of limitation and efficiency;
for example, processing cycles and system modification may be
established on the basis of a consensus of users rather than on
the prerogative of one State. Similarly, State particular
enhancements are limited to those which can be effected without
disturbing the configuration of the basic system. However,
centralized system maintenance will be performed on a timely
basis. In addition, since processing is provided by EPA, the
State does not need to acquire an automated capability of its
own to process UIC data.
(2) Distributed Implementation Alternative
The distributed implementation alternative includes the
implementation of the UIC Information System at a State facility.
This option does not eliminate the central option, but adds
another dimension. In the distributed mode using the
decentralized option, copies of the software would interface
remotely with the Federal Reporting System.
The impact on the EPA Headquarters of the distributed
approach results in a major coordination activity for system
maintenance and modification. In addition, system development is
more complex in that the system must be transportable and
therefore as machine independent as possible. However, making
the system available to the States on their own facilities may
encourage operation of standard systems which simplifies the EPA
monitoring function.
IV-2 4
-------
The impact on the States is primarily one of greater use of
State resources. The State is responsible for operation of the
system and for implementing the changes disseminated by EPA.
However, processing cycles are purely at State discretion and
limited local enhancement is feasible so long as it does not
disrupt the integrity of supplied software. Any enhancement,
however, could seriously jeopardize the standardized aspects of
the system and may require significant additional maintenance
costs.
It may be observed that although there are impacts of each
alternative on EPA and the States, they are not conclusive. Costs
will play a large part in the decision. A cost analysis is
provided in the next section.
(3) Cost Analysis of Alternative Implementation Strategies
A cost analysis of the alternative implementation strategies
was conducted. The cost analysis technique is illustrated in
Exhibit IV-16A. Costs from the centralized and distributed
approaches were developed first on the basis of costs associated
with a State which would operate the system in a centralized mode
and a State which uses the distributed mode. An additional
dimension was added by developing costs for both a small volume
State and a large volume State (Exhibits IV-17 and IV-18). The
changes from the centralized mode reflect additional training
and operating costs at the administrative agency resulting from
the system's residence at the State facility.
In addition, the fixed costs for design and development were
modified for the distributed alternative (Exhibit IV-19), as well
as implementation and operation at EPA Headquarters (Exhibit IV-
20). The modifications to the design and development costs
represent the additional effort to develop a system which is as
machine independent as possible to permit implementation on a
variety of State computers. Changes to the implementation and
operation costs at EPA Headquarters reflect increased
maintenance costs because of additional packaging of system
changes, and coordination and dissemination to States in which
the system is implemented. Exhibit IV-21 is a summary chart
illustrating the implementation, operation, and life cycle costs
for a State under the distributed alternative. The chart shows
significantly increased costs resulting from the processing and
maintenance being done by the individual State rather than
central ly.
Three scenarios were then selected which represented various
combinations of State roles. The three scenarios are presented
in Exhibit IV-22. They represent a range of possible actions by
the States in response to the UIC Program and EPA's initiative
in system development.
IV-2 5
-------
EXHIBIT IV-16A
ALTERNATIVE IMPLEMENTATION STRATEGIES COST ANALYSIS
ALTERNATIVE III DESIGN AND
DEVELOPMENT COSTS (CENTRAL)
ALTERNATIVE 111
SYSTEM DESIGN AND
DEVELOPMENT (DISTRIBUTED!
I I I
EPA HEADQUARTERS
ALTERNATIVE III DISTRIBUTED
IMPLEMENTATION AND OPERATIONS COSTS
ADMINISTRATIVE AGENCY
ALTERNATIVE III CENTRAL
IMPLEMENTATIONS AND OPERATIONS
(LARGE/SMALL)
IMPLEMENTATION SCENARIOS
aiiT^.-rta an.!M
Hiii» iiHw
ALTERNATIVE SCENARIO LIFE
CYCLE COST ANALYSIS
I I
1 T
ADMINISTRATIVE AGENCY
ALTERNATIVE III DISTRIBUTED
IMPLEMENTATION AND OPERATIONS COSTS
(LARGE/SMALL)
CENTRAL/DISTRIBUTED IMPLEMENTATION
AND OPERATIONS COST
SUMMARY
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE III - DISTRIBUTED SMALL
Cost
Elements
Personnel Resources
Computer Resources
Supplier/
Other
Totals
Contractor
EPA
Computer
Support
EPA
Clerical
EPA
Professional
Processing
Storage
Communication
Out ol Pocket
Eipeniet
Opportunity
Costs
Total
Implementation
Data
Conversion
11,400
1,000
2,400
1,000
2,300
200
13,900
4,400
2,600
18,300
7,000
Training
3,700
500
900
1,200
700
4,400
Prototype
Operation
10.200
5.000
14.400
3.800
12.500
200
22.900
23,200
46,100
Tola!
Implementation
25,600
6,500
17,700
6,000
14,800
1,100
41,200
30,200
71,400
First Year
Operating
Data Entry &
Update
1,000
900
2.300
5.300
200
6,800
4,200
11,000
Pincesiing &
Reporting
Management
& Analyst*
3,800
4,300
7,200
19,200
200
19,400
15,300
34,700
L^j5lQ0_
-7, 500
.4,200
200
200
9,100
9, 300
System
Maintenance
16,700
11,700
11,700
20,900
32,600
Total Hut
Year
1.300
21,500
6.800
21,200
36,200
600
38,100
49,500
87,60C
Life Cycle
Operating
Oata Entry &
Update
Processing &
Reporting
7 °00
5-,-SOO
5-rOOO
53, ftOO
12-.JOO
39,800
29,300
106,100
1, ion
-23.,-2Q0_
L08,300
6£).,.8Q0
215,500
1.100
107.200
Management
& Analysis
8,800
41,400
1,100
1,100
50,300
51,400
Syitem
Maintenance
i
Total
Life Cycle
32 , 500
125,300
37,600.
123,100
214,800
4 ,400
251,700
273 ,5o0
404,uOC
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE _ III DISTRIBUTED LARGE
Cost
Efeiiieuls
Peisumit:! flL'souicei
Ccj*ii|iiiicc Resumces
T ulals
CoQtiadoi
EPA
Compute!
Suppuil
EPA
Clciic*!
EPA
Fioteiuuual
Piuceiting
Sloiage
CoilllltlHliCdllUII
Su|iplicf /
Oihcf
Qui ol Pochil
E«|iemet
OpIiDitunily
Cost*
lulal
Oil*
Coaveiiiou
423000
6800
11600
1700
3900
-
-
4500
431400
20100
451500
Tiaiuiog
3700
1000
3500
1500
-
-
-
800
4500
6000
10500
Implementation
.
Piotulype
Opeitlioa
10200
2500
4500
13500
17900
500
28600
20500
49100
lulii)
4 36900
10300
19600
16700
21800
-
-
5800
464500
46600
511100
Data Enliy &
Update
28100
1000
22000
2300
14700
-
-
300
43100
25300
68400
Piuctniny &
fleputiiiig
-
3800
16800
63000
37200
-
-
300
37500
83600
121100
Fiisl Yeai
Opcialing
Maiiageuieut
& Analytic
-
-
2000
10200
-
-
-
200
200
12200
12400
Syttem
M«iulcoiince
-
16700
-
4200
2 3000
-
-
-
2 3000
20900
43900
TuUl Fiivl
Veai
28100
21500
40800
79700
74900
-
-
800
103800
142000
245800
Dill Euliy ft
(Indite
155300
5500
121600
12700
81200
-
-
1700
238200
139800
378000
Piocetiing ft
llepoa ling
-
21000
92800
348100
205600
-
-
1700
207300
463000
670300
Life Cycle
Ojieuliug
Management
ft Aaalytit
-
-
17.100
56400
-
-
-
1100
1100
67400
68500
Syileui
Maiaieoauce
-
92300
-
23200
127100
-
-
-
127100
115500
242600
Iota)
Lift Cycle
592200
129100
245000
457100
435700
-
-
10300
1038200
832300
1870500
<
-------
ALTERNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM DESIGN AND DEVELOPMENT
ALTERNATIVE ill DISTRIBUTED
Cost
Elements
Personnel Resources
Computer Resources
Supplies/
Other
Totals
Contractor
EPA
Compoter
Support
EPA
Clerical
EPA
Professional
Processiny
Storaye
Communication
Out of Packet
Expenses
Opporlunity
Costs
Total
Detailed
Systems
Desiyn
93,600
16,300
14,400
108,000
16,300
124,300
Program
Specifications
36,500
6,700
36,500
6,700
43,200
Proijrani
Development
52,300
1.1,500
12,000
200
64,500
11,500
76,000
Ducuiiieutatiuii
Preiiaration
46,800
13,000
3,400
50,200
13,000
63,200
System
Test
46,800
10,600
¦20,200
200
200
67,400
10,600
78,000
Tutal
Development
Costs
276,000
58,100
32 .200
200
18,200
326,600
58,100
384,700
-------
ALTEHNATIVE SYSTEM CONCEPTS COST ESTIMATES
SYSTEM IMPLEMENTATION AND OPERATIONS
ALTERNATIVE 111 " DISTRIBUTED EPA - FIXED COST
Coil
Ctetneiils
Pcismiuil Resumed
Computet nesumccs
Supplies/
Oihei
1 utals
Coniiactoi
EPA
Computet
Suppoil
EPA
Cleiical
EPA
PiulettionaJ
Piocniing
Sludge
Cuniniiiniciiiim
Out al Pucfcet
Eipemn
Oppuitunity
Cuiti
1 ulat
luiplciueiiiatiuii
Oil*
Convetitoo
Ttaiuing
Piululype
Opeitlioo
6,40C
1,00C
1,20C
3,400
8,300
200
1,60C
200
16,700
5 ,600
22,300
Taul
Implementation
6,40C
1,00C
1, 20C
3,400
8,300
200
1 ,60C
200
16,700
5,600
22,300
Fiisl Ycai
Opcialiug
Data Euliy &
Update
Pioceiiisig &
Repatliiig
Maougoiiicnl
& AnatyM
Sytlem
Maintenance
..
21,100
. -
5,300
29,500
- ... ..
6 ,00C
. .
35,500
26,400
61,900
Total Fini
Yeai
21,100
5,300
29,500
6, OOC
35,500
26,400
61,900
Life Cycle
Updating
Ddla Entiy &
Update
Piocetiing &
ftepuitiug
Management
& Aualyiii
System
Maintenance
116,600
29,300
163,000
33 ,200
¦ ¦
196,200
145,900
342,100
Total
tile Cycle
6,400
117,600
1,200
32,700
171,300
200
34,800
200
212,900
151,500
364,400
-------
EXHIBIT IV-21
LIFE CYCLE IMPLEMENTATION & OPERATIONS
COST SUMMARY
CENTRAL HL
DISTRIBUTED.
Out
of Pocket
Oppor-
tunity
Total
Out
of Pocket
Oppor-
tunity
Total
SMALL
Implementation
33.3
7.7
41.0
41.2
30.2
71.4
Operation
132.6
139.1
271.7
210.5
273.5
484.0
Life Cycle
165.9
146.8
312.7
251.7
303.7
555.4
LARGE
Implementation
454.9
16.5
471.7
464.5
46.6
511.1
Operation
39'2.5
664.3
1056.8
573.6
784.6
1358.2
Life Cycle
847.4
681.1
1528.5
1038.1
831.2
1869.3
-------
SCENARIOS FOR CENTRAL VS DISTRIBUTED
ALTERNATIVE IMPLEMENTATIONS
Scenario
State
CENTRALIZATION ALTERNATIVE
Primacy State
Own System
EPA Central System
Non-Primacy
State
1
Small
6
4
1
Large
5
1
2
2
Small
4
5
2
Large
4
2
1
3
Small
1
7
3
Large
5
1
1
Scenario
State
DISTRIBUTED ALTERNATIVE
Primacy State
Central
Own System EPA System
Distributed
EPA System
Non-Primacy
State
1
Small
6
2
2
1
Large
5
-
1
1
2
Small
4
3
2
1
Large
4
1
1
1
3
Small
1
4
3
3
Large
5
-
1
1
-------
Utilizing these assumptions we have developed the full costs
for the alternative implementation strategies under the
scenarios. These costs are presented in Exhibit IV-23. The
additional cost burden of the distributed approach is clear in
this summary. The costs are due to the additional system
maintenance and operational costs attributable to the distributed
alte rnat ive.
The impact on EPA, as shown by the scenarios, increases
significantly as the States decide to accept the system at their
own facilities. This cost must be balanced against the potential
advantages of the distributed alternative, as opposed to
advantages of the centralized alternatives, to EPA and the States.
As a result, this is a policy decision which goes beyond the
domain of this study. However, we have assumed that ODW would
proceed with the centralized approach for this system. The
reasons for this assumption are:
The cost impacts on EPA for a distributed approach would be
signi ficant
We believe the negative aspects of State use of a centralized
system could be alleviated through proper system design and
confidentiality procedures.
The details of the recommendations are presented in the next
chapter.
IV-26
-------
ALTERNATIVE SCENARIOS LIFE CYCLE COST PROJECTIONS
(DOLLARS IN THOUSANDS)
CENTRAL
DISTRIBUTED
Alternative
Cost
Out-of-Pocket
Opportunity
Annual
Out of Pocket
Opportunity
Annual
Scenario
Components
Expenses
Costs
Total
Expenses
Costs
Total
System Design & Development '
274.6
48.4
323.0
326.6
58.1
384.7
1
EPA Headquarters Implementation
and Operations
180. 3
127.2
307.5
212.9
151.2
364.1
Administrative Agency
Implementation and Operations
2524.3
2096.2
4620.5
2886.6
2560.1
5446.7
LIFE CYCLE
2979.2
2271.8
5251.0
3426.1
2769.4
6195.5
System Design & Development
274.6
48.4
323.0
326.6
58.1
384.7
2
EPA Headquartors Implementation
and Operations
180.3
127.2
307.5
212.9
151.2
364. 1
Administrative Agency
Implementation and Operations
3,703.5
3,070.9
6,774.4
4,065.8
3,534.8
7,600.6
LIFE CYCLE
4,158.4
3,246.5
7,404.9
4605.3
3744.1
8 349.4
System Design & Development
274.6
48.4
323.0
326.6
58.1
384.7
3
EPA Headquarters Implementation
and Operations
180. 3
127.2
307.5
212.9
151.2
364.1
Administrative Agency
Implementations and Operations
3353.8
. 2830.2
6184.0
3801.9
3451.0
7252.9
LIFE CYCLE
3808.7
3005.8
6814.5
4341.4
3660.3
8001.7
x
i
09
00
-------
V. RECOMMENDATIONS
-------
V. RECOMMENDATIONS
The system concept recommended, Alternative III, consists of both
manual and automated support activities to the UIC program at the
administering level. Automated support is provided to those program
functions which are characterized by high volume of data, necessity
for timely response, and effective use of available resources. The
manual support activity is provided to those functions which are
characterized by low volume of data, and fewer requirements for
expeditious action.
We have also recommended a centralized approach for
implementation of the UIC Information System. Another consideration
in implementation, not discussed above, is the phasing of
implementation. The UIC Information System, when implemented, will
support the initial set of designated States, the majority of which
are oil and gas producers. Since the major underground injection
activity relates to the production of oil and gas, it is imperative
that the system have the capability, as a minimum, to service the oil
and gas related activity. Although there is underground injection
activity not related to oil and gas within many designated States,
when compared against the oil and gas related wells this volume is
relatively insignificant. We recommend that the system be brought up
in a phased approach both in terms of function and data maintained.
We recommend at the outset of system operation only data relating to
oil and gas related activities be maintained on the automated files.
We anticipate that after the system has been operational for some time,
and a level of confidence has been developed, the additional injection
activity data can be included.
This chapter describes the recommended system automated
activities and manual activities and a phased implementation plan for
the recommended system.
1. RECOMMENDED UIC SYSTEM ACTIVITIES
The UIC management information system is designed to support
program administrator activities, whether they are performed by a State
or an EPA Region. At the same time, the system is flexible enough to
support the monitoring activity of EPA by providing a base of summary
level information. The system is comprised of several major activities
which must be performed within the UIC system in order to achieve
previously defined objectives. The automated activities include:
Track permit applications and maintain permits
Maintain UIC operations inventory
V-l
-------
Develop and track inspection schedule
Screen and maintain self-monitoring reports and violations
history
Respond to inquiries.
In addition, there are manual activities which handle low volume data
and are analytical in nature. These are:
Screen and maintain inspection findings
Initiate and track enforcement actions
Analyze program effectiveness
Exhibit V-l shows the automated and manual activities, inputs,
outputs, and internally maintained information provided by the
recommended UIC management information system.
Each activity is also composed of certain subactivities, inputs,
outputs and internally maintained information requirements. These are
described in the paragraphs which follow. Reports produced by the
automated system are listed in Exhibit V-2.
(1) Activity 1: Track Permit Applications and Maintain
Permits
Exhibit V-3 shows the inputs, outputs, and subactivities
which will be performed in this activity. Activity 1 identifies
facilities that have been sent permit applications, and tracks
the status of the applications. When an application is reviewed
and approved, the information on the approved permit is
maintained. Activity 1 consists of the following subactivities:
Initiate Permit Applicant File - When an application is sent
to a prospective permittee, the basic applicant and
application information will be entered into the UIC
information systems by the program permit staff.
Screen Incoming Applications - As an application is
submitted, it is screened Eo"r completeness by the permit
staff who then enter an application received status into
the Permit Applicant record.
Identify Delinquent Applications - Periodically, the Permit
Applicant File will be scanned and those applicants who have
not submitted applications by the application due date will
be reported. The permit staff will notify the applicants
that their applications are overdue.
V-2
-------
UIC INFORMATION SYSTEM
DESIGN ALTERNATIVE 3
EXHIBIT V-1
LEVEL OF AUTOMATION
Track Parmit
Applications and
Maintain
Permits
Permittee
Maintain
UIC Operations
Inventory
Archival
Data
Develop and
Track
Inspection
Schedule
Inspection
Schedule File
Inspection
Data
Inspection
Compliance
Violations
Self
Monitoring
Reports
Initiate and Track
Enforcement
Action
Enforcement
Action
Pile
Enforcement
Guidelines
Enforcement
Action Notice
Program
Etfecti
Answer
Special
Inqufri
o System Management
Decentralized
Centralized
c Management Reporting
Batch Status
Batch Inquiries
Manual Analyses
» Data Management
Centralized
.. Conventional Files
. . DBMS
Decentralized
.. Conventional Files
Processor
Centralized
. . EPA Processor
(NCCor WCC)
Decentralized
. . Single State Processor or
. . Individual Agency Processor
~
¦ Automated for
-------
EXHIBIT V-2
UIC INFORMATION SYSTEM
REPORTS
ACTIVITY AND REPORTS
USE
FREQUENCY
Permit Application Tracking and Maintenance
Delinquint Applications Report
Exception Report Indicates Overdue Application Submittals
Triggers Notification to Operator of Overdue Status
Monthly
Permit Activity Report
Management Report Provides Oata on Number of Permits
Issued, Types, Recipients, and Conditions
Quarterly
Maintain UIC Operations Inventory
Inventory Maintenance Report
Error Oetection Tool for System Managers. Lists Additions,
Oeletions, and Status Changes
Quarterly
i Inventory Status Report
Provides Inventory Update Information with Summary and
Control Totals for Use by the Program Administrator
Quarterly
Oevelop and Track Inspection Schedule
Inspection Schedule
List of Scheduled Inspections which Identifies the Operation
to be Inspected and the Date
Monthly
Scheduled Inspection Assessment Report
Management Report which Inspection Schedules,
Completions and Delays
Quarterly
Screen and Maintain Self-Monitoring Reports
Notice of Violation
Exception Report Indicating a Violation was Found.
Triggers a Notice to the Operator
Quarterly
Violations List
List of Violations Detected, for Review and
Follow-up by Enforcement Staff.
Quarterly
Compliance Report
Management Report of Complianc&Activity Indicating
Number and Types of Violations, Compliance and
Inspection Actions
Quarterly
Answer Special Inquiries
Ad Hoc Reports
Response to Special Requests for Information
Such as: Status of Permits, Enforcement Actions; Total
Activities; Individual Operator Status
Monthly
-------
TRACK PERMIT APPLICATIONS AND MAINTAIN PERMIT
DATA SUB ACTIVITIES OUTPUT RECIPIENT
Initiate Permit Applicat File
Screen Incoming Applications
Identity Delinquent Applications
Modify Applicant Status and
Add Permit Information
Update Permittee Record
with Modification Data
Facility
Operator
Proyram
Permit
Stall
Proyram
Inventory
Maintenance
Stall
Permit Modification
- Condition
Changes
Notice of
Application
Overdue
¦ Permit
Activity
Report
Delinquent
Application
Report
¦ Permit
¦ Permit
Application
Permittee
Information
- Identification
- Location
- Status
Permit Conditions
- Number
- Compliance
Schedule
.. Milestone Dates
- Pressure
- Fluid Vuluines
- Reporting Frequency
Permit Application
- Identification
- Location
- Contact
- Operation Type
- Number Wells/lloles
- Receiver Formation
Data
- Proximity Well
Information
Permit Applicant Information
- Applicant Name
- Application Sent Date
- Application Due Date
- Application Status
Permittee Information
- Number
- Ownership
- Location
- Cotiditimis
- Schedule
- Receiver Formation Data
Internally Maintained Data
-------
Modify Applicant Status and Add Permit Information - When
a permit application is approved and a permit issued, the
permit staff will acknowledge this by updating the Permit
Applicant record to Permittee status. The UIC system will
enter all pertinent permit information onto the records.
Update Permittee Record with Modification Information - When
a facility operator requests and is granted a modification
to his permit, the modified information will be entered onto
the Permittee record through the UIC system.
The input required to support these subactivities includes:
Permit Application - Provides the ownership/operator
identification information, the operation location and
classification, and the operation technical information.
This information is supplied by the facility operator.
Permit Conditions - Provides the conditions set forth in
tne permit such as allowable pressures and volumes,
construction compliance schedule for a new facility, and
required self-monitoring reporting frequency. This
information is supplied by the program permit staff.
Permit Modifications - Provides the revised permit
information when a permit modification is granted. This
information is supplied by the program permit staff.
The internally maintained information for this activity will
include:
Permit Application Information - The permit application will
identify the applicant by name, location, and classification
of operation. Additionally, such information as the date
the application was sent, the date the application is due,
and the current status of the application will be maintained.
This information will support the application tracking
activity.
Permittee Information - The permit information will identify
the specific conditions imposed upon the facility operator.
These include the allowable pressure he must comply with in
his injection operation, and the allowable volume of fluid
that can be injected. In the case of construction permit
for a new facility or a facility modification, the
information will identify the construction compliance
schedule which the facility operator will follow.
The major output of this activity includes:
Permit Application - This application form is sent to the
facility operator for completion and submittal to the
program permit staff.
V-3
-------
Permit - Upon approval of the permit application, the Permit
is issued to the facility operator. With the Permit, the
facility can now legally operate.
Delinquent Application Report - This report identifies those
applicants whose application submittals are overdue. It is
sent to the program permit staff who follow up by notifying
the applicant that the application is overdue.
Permit Activity Report - This report provides information
tor the Program Administrator to assess the effectiveness
of the permit process. It provides data on the number of
applications outstanding, the number of permits issued, the
type of permits issued, the permit recipients, and the
conditions imposed upon them.
(2) Activity 2: Maintain UIC Operations Inventory
Exhibit V-4 shows the inputs, outputs, and subactivities
required to initiate and maintain the UIC operations inventory.
Activity 2 initiates and maintains, through periodic updates, an
inventory of all underground injection operations, both active
and inactive for which there is available data. This activity
will be performed by the programs inventory maintenance staff.
Major subactivities include:
Record Permit Information Operations Inventory - Selects
that information from the Permit which is relevant to the
operations inventory, and records this data on an inventory
record. This ensures that all new underground injection
operations are entered onto the operations inventory.
Update Operations Inventory with Archival Data - The
operations inventory will consist of both active and
inactive underground injection operations. The data for
entering and maintaining the inactive operations will come
from archival records. An operations inventory record will
be created and maintained for those operations that have
archive records.
Modify Operations Inventory - Periodically, there is a need
to modify existing inventory records. The modification is
usually due to a change in status of the underground
injection operation. Status changes include plugging,
abandonment, or an operational status change. Additionally,
change in ownership or contact will initiate an inventory
modification.
The input required by this activity includes the following:
Permit Data - This is the information on the permit that is
necessary to initiate an inventory record. The data provides
V-4
-------
MAINTAIN UIC OPERATIONS INVENTORY
SOURCE DATA SUB ACTIVITIES OUTPUT RECIPIENT
Record Permit Information
in Operations Inventory
Update Operations Inventory
with Archival Data
Modify Operations
Inventory
Facility
Operator
Proyram
Inventory
Maintenance
Activity
Inspector
Program
Inventury
Maintenance
Staff
Report
Abandoned Well
Findings
¦ Notification
Abandoned or
- Pluyyed Well
e Inventory
Update
List
Inventory
Status
Report
Archival
Information
- Well Number
- Permit Number
- Location
- Status
- Type
Permit Data
Operation Type
State Code
Federal ffeyion Code
Operation Location
- Permit Basis
Number of Wells
Operation Status
Internally Maintained Information
¦ UIC Operations
Inventory
- Well Identification
- Well Status
- Permit Number
- Permit Oate
- Pluyyed Date
m
X
I
oo
-------
operation identification, location, permit basis, number o£
wells affected, and operational status information. This
information is supplied by the program inventory maintenance
sta ff.
Archival Information - Provides data relating to inactive
and active wells which have been in existence for a number
of years. The information may include well number, permit
number, location, classification, and status. The
information will be supplied by the program inventory
maintenance staff.
Plugged or Abandoned Well Notification - Provides
information indicating a change in status of an operating
well. This information is supplied by the facility operator
and can be in the form of a notice or a plugged well permit
application.
Inspection Report - Provides information concerning
operation abandonments and pluggings which have not
previously come to the attention of the inventory
maintenance staff. This information is supplied by the
inspector.
The required internally maintained information for this activity
includes:
UIC Operations Inventory - The UIC Operations Inventory is
the repository of all Information pertaining to active and
inactive underground injection operations. The inventory
identifies the operation ownership, location, contact point,
classification, status, permit number, and pertinent dates.
The output of this activity will include:
List of Inventory Updates - Each time the inventory is
updat ed the UIC system will provide the inventory
maintenance activity with a listing which shows the
additions, deletions, and status changes which caused the
update to occur.
Inventory Status Report - A report providing the inventory
update information summary and control totals depicting the
current inventory will be produced for the program
administrator.
(3)
Activity 3: Develop and Track Inspection Schedule
Exhibit V-5 shows the inputs, outputs, and subactivities
required to develop and track inspections. Activity 3 develops
a schedule of inspections based upon number of operations, and
estimated time for inspection. Once the schedule is developed,
V-5
-------
DEVELOP AND TRACK INSPECTION SCHEDULE
SOURCE DATA SUB-ACTIVITIES OUTPUT RECIPIENT
Program
Support
Staff
P ^am
A dm trator
Inspection
Staff
Inspection
Schedule
Scheduled
Inspection
Status
Report
Requests for
Inspection
Operator
Location
Reason for
Inspection
Operation inionud»«"
- Estimated Time per
Inspection
- Inspection Priorities
Permittee Information
- Owner/Contact
- Location
- Classification
- Status
Inspection, Schedule
- Assigned Inspector
- Inspection Dates
- Inspection Sites
- Inspection Status
Internally Maintained Data
Track Scheduled Inspections
Develop Inspection Schedule
Update Inspection Schedule
-------
the system will track the schedule to ensure that scheduled
inspections are being performed. This would be an optional
capability utilized at management's discretion. Major
subactivities include:
Develop Inspection Schedule - Based upon average time
between inspections, and the governing inspection
priorities, the UIC system will produce an annual schedule
of facility site inspections.
Track Schedule Inspections - Periodically after the
scheduled inspection date, the system will check whether the
inspection findings have been filed, and update the
inspection status accordingly.
Update Inspection Schedule - From time to time the program
inspection statf will receive requests to conduct
unscheduled inspections. In this case, the UIC system will,
upon receiving inspection request information, add the
inspection to the schedule.
The input required by this activity includes:
Operation Information - The inspection schedule will be
based on the average time between inspections required, and
the inspection priorities which have been specified. This
information will be supplied by the program support staff.
Request for Inspection - At times, it will be necessary to
conduct inspections which have not been scheduled. These
inspections are usually requested by members of the program
support staff. The request for inspection information
includes identification of the operator to be inspected, and
the facility location.
The internally maintained information will include:
Permittee Information - The identifying information that
will be included on the exception report is provided by
the permittee file. This includes the owner name, operation
location, operation classification and status.
Inspection Schedule - Provides the means with which to track
inspections by scanning the inspection status. The
inspection schedule identifies the date of inspection, and
the site of inspection.
The output generated by this activity includes:
Inspection Schedule - This is the list of inspections
scheduled to be conducted during the upcoming year. It
identifies the site, and the date of inspection.
V-6
-------
Scheduled Inspection Assessment Report - This is a periodic
report to program management which presents an assessment
of how the inspection process is working. Through this
report, management can make decisions and assign priorities
regarding future inspections.
(4) Activity 4: Screen and Maintain Self Monitoring Reports
Exhibit V-6 presents the inputs, outputs, and subactivities
required to screen and maintain operator self-monitoring reports.
Activity 4 consists of two types of screening, a screen to
determine if an operator has reported on schedule, and a screen
of the operator's report to determine compliance with permit
conditions. The major subactivities include:
Screen for Operators Failing to Report - Each operator is
requi red to subm i t self-monitoring reports according to an
agreed upon schedule. This subactivity consists of
determining whether or not an operator's report has been
submitted on the day it is due. This is done by screening
a list of reports due on this date and determining if the
report in fact has arrived.
Compare Self-Monitoring Report to Permit Conditions - This
subactivity consists of comparing the values reported on
the self-monitoring report to the values assigned in the
operator's permit. These values may include pressure, volume,
and total dissolved solids within the groundwater. Through
this screening, possible operator violations or other
problems can be highlighted along with previous operator
history.
Initiate Violation and Compliance Files - When the
inspection findings indicate a violation, this information
will be used to initiate a Violations and Compliance record
for the particular operation. This record will enable the
program management to maintain a historical record of
violations and compliance of each operator.
Update Violation and Compliance File - When corrective
action is taken by the facility operator, the system will
note this action through updating the violation and
compliance record of that operator. The information which
identifies the corrective action will come from either an
inspector's report or an acknowledgement from the operator.
The inputs required by this activity include:
Operator Self-Monitoring Report - This is the report
submitted by the facility operator which details the values
obtained when the operation was monitored during the period.
The information consists of operator identification,
V-7
-------
SOURCE
SCREEN AND MAINTAIN SELF MONITORING REPORTS
DATA SUB ACTIVITIES OUTPUT
RECIPIENT
Facility
Operator
Pruijram
Administrator
Facility
Operator
Notice of
Violation
Compliance
Report
Notice of
Correction
Sell-Munitoring
Report
- Operation 111
- Operation Type
- Report Date
- Reported
Values
Screen for Operators
Failiny to Report
Compare Self-Monitoriny
Report to Permit Conditions
Initiate Violation anil
Compliance Records
Update Violation anil
Compliance Files
Internally Maintained Data
s Permittee Information
- Reporting Schedule
- Permit Conditions
Compliance Information
- Report Dale
- Violation Status
- Criteria
- Reported Value
- Permitted Value
Violations Information
- Violation Type
- Violation Date
- Violation Severity
- Correction Status
- Detection Mechanism
cn
m
X
X
CO
-------
operation classification, reporting dates, and reported
values.
Notice of Correction -Provides evidence that the facility
operator has taken measures to correct what was in violation.
It identifies the corrective action and the date it was
taken. This data is used to update the operator's violation
and compliance history.
The internally maintained information includes:
Permittee Information - This information includes the permit
conditions and the self-monitoring reporting frequency.
Violations and Compliance Information - This internally
maintained data file will contain a history of all violations
by an operator. Included in the file are the type of
violation, the date of violation, the severity, the
correction status, and the mechanism of violation detection.
Also included are the criteria which were not in compliance,
the reported and permitted values of the criteria.
The output generated by this activity are:
Notice of Violation - This information is sent to the
facility operator with a copy to program enforcement. It
is used to notify the operator of a violation and to initiate
corrective actions.
Violations List - This is a list of all violations that were
detected by those inspections conducted during the previous
period. It provides the enforcement staff with a list of
violations to follow up on.
Compliance Report - This is a report of the compliance
activity during the period. It identifies non-compliance,
the conditions which were violated, the overall number of
compliance actions during the period and a summary of all
inspection activity during the period.
(5) Activity 5: Answer Special Inquiries
Exhibit V-7 depicts the inputs, outputs, and subactivities
required to answer special inquiries. Activity 8 will system
support for requests for specialized types of information not
currently provided to the various levels of program management.
Major subactivities include:
Identify Required Information - This subactivity consists
of determining the information required to satisfy special
requests and identifying where the information resides.
V-8
-------
ANSWER SPECIAL INQUIRIES
SOURCE DATA SUB ACTIVITIES OUTPUT RECIPIENT
Answer to
Special Inquiry
Federal Ayencies
Proyrain Administration
Congress
General Public
Environmental Groups
Proyrain
Administration
¦ Congress
Special Interest
Groups
Federal
Ayencies
Public
¦ Requests fur
Special
Information
- Permit Issuances
- Violations
- Enforcement
Actions
- Estimated
Proyram Growth
- Geographic
Breakdown
Internally Maintained Information
Permittee Information
Operations Inventory
Compliance Profile
Violations History
Enfurccincnt Actions
Identify Required
Information
Compile Information
Into Desired Format
Respond to Inquiry
-------
Compile Information into Desired Format - This subactivity
consists of gathering the information once it has been
located, and compiling the data into a format which
facilitates its use by the requestor.
Respond to Inquiry - This subactivity consists of packaging
the formatted response and delivering it to the requestor.
Input required by this activity consists of:
Request for Special Information - This is the request by
interested parties which identifies what information is
required, and may also identify the format it is to be
presented in.
The internally maintained information required by this activity
consists of whatever data files exist. It is from the UIC
information system data files that these requests will be
satisfied. These data files include:
Permittee Information
UIC Operations Inventory
Violations and Compliance Information
Enforcement Actions Information.
The output generated by this activity includes:
Answer to the Special Inquiry - Which is prepared and
packaged in a format that facilitates its use by the
requestor.
(6) Activity 6: Screen and Maintain Inspection Findings
Exhibit V-8 shows the inputs, outputs, and subactivities
required for screening and maintaining inspection findings.
Activity 6 is a manual process which screens the findings
presented in the inspection report and initiates and updates
compliance and violation history as required. Major subactivities
include:
Screen Inspection Findings - This subactivity consists of
manually reviewing the inspection report findings for
completeness and accuracy, and screening the reported
violations with respect to the permit conditions.
Initiate Violation and Compliance Record - When the
inspection findings indicate a violation, this information
will be used to initiate Violations and Compliance record
for the particular operation. This will enable the program
V-9
-------
SCREEN AND MAINTAIN INSPECTION FINDINGS
SOURCE DATA SUB ACTIVITIES OUTPUT RECIPIENT
Proyrain
Enforcement
Staff
Facility
Operator
Facility
Operator
Program
Administration
Inspection
Staff
Notice of
Violation
Compliance
Report
Violations
List
Notice of
Correction
Inspection Results
- Operator III
- Operation Type
- Inspection Date
- Violation Status
- Criteria Violated
- Reported Values
- Opinions and
Conclusions
Screen Inspection
Findinys
Update Compliance and
Violations Files
Initiate Violation and
Compliance Records
Internally Maintained Information
Permittee Information
Inspection Schedule
Compliance Information
- Report Date
- Violation Status
- Criteria Out of Compliance
- Reported Value
- Permitted Value
Violation Information
- Violation Type
- Violation Date
- Violation Severity
- Correction Status
- Detection Mechanism
-------
management to maintain a historical record of violations
and compliance.
Update Violation and Compliance File - When an inspector's
report or notice trom the operator indicates that corrective
action has been taken, an update to the Violations and
Compliance file is manually prepared.
The inputs required by this activity include:
Inspection Results - The completed Inspection Report will
provide the findings information that is the basis for
intiating the violation and compliance records.
Permit - The hard copy permit will be used in conjunction
wi th The inspection report to analyze compliance.
Notice of Correction - Provides evidence that the facility
operator has taken measures to correct what was in violation.
It identifies the corrective action and the date it was
taken. This data is used to update the operator's violation
and compliance history.
The internally maintained information includes:
Violation Information - This internally maintained data file
will contain a history of all violations by an operator.
Included in the file are the type of violation, the date of
violation, the severity, the correction status, and the
mechanism which detected the violation, the status of the
violation, which criteria were not in compliance, the
reported and permitted values of the criteria.
The output generated by this activity includes:
Notice of Violation - This information is sent to the
facility operator with a copy to program enforcement. It
is used to let the operator know there is a violation and
to initiate corrective actions.
Violations List - This is a list of all violations that were
detected by those inspections that occurred during the
period. It provides the enforcement staff with a list of
violations to follow up on.
Compliance Report - This is a report of the compliance
activity during the period. It identifies non-compliance,
the conditions which were violated, the overall number of
compliance actions during the period and a summary of all
inspection activity during the period.
V-10
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(7) Activity 7:
Initiate and Track Enforcement Actions
Exhibit V-9 shows the inputs, outputs, and subactivities
required to initiate and track enforcement actions. Activity 7
is a manually performed activity which determines the required
enforcement action based upon the violation, initiates an
enforcement action file when the action requires time to complete,
and tracks the status of the action until resolution. Major
subactivities include:
Determine Enforcement Action - This subactivity consists of
comparing the violation severity and type to a set of pre-
defined enforcement guidelines and selecting the indicated
action response. The enforcement guidelines are supplied
by the program enforcement staff, and the list of violations
is supplied by the program compliance monitoring activity.
Initiate Enforcement Action - In the event that the
prescribed action is time-consuming, the enforcement staff
will open an enforcement action folder in the enforcement
action file in order to monitor the action from initiation
to completion. In addition, a schedule for the enforcement
activity is prepared. When the prescribed enforcement action
is a phone call, this will not be necessary. All enforcement
actions will be centered on a log indicating the action,
actual or scheduled activity date, and status.
Track Enforcement Activity - This subactivity consists of
periodically scanning the enforcement action log and
schedule to identify upcoming events which must be addressed.
It also involves preparing enforcement action notices for
the enforcement action file and entering the date in the
appropriate status column of the log when an event has
occurred so that the enforcement action schedule and status
log can be maintained.
Close Out Enforcement Action - This subactivity consists of
moving the enforcement action folder to the closed file and
entering the date in the appropriate status column of the
log when the action has been resolved.
Inputs required by this activity include:
List of Violations - This information is supplied by the
compliance monitoring activity and provides the necessary
violation information to initiate an enforcement action.
Enforcement Guidelines - Provides the basis for determining
the required enforcement action. This information is
supplied by the program enforcement staff.
V-ll
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INITIATE AND TRACK ENFORCEMENT ACTIONS
SOURCE DATA SUB ACTIVITIES OUTPUT RECIPIENT
Determine Enforcement
Action
Initiate Enforcement
Action Record
Track Enforcement
Activity
Close Out Enforcement
Action
Facility
Operator
Compliance
Monitoring
Activity
Program
Administrator
Program
Enforcement
Staff
§ Enforcement
Action
Schedule
Enforcement
Activity
Report
Enforcement
Action
Notice
¦ Enforcement
Guidelines
- Violation
.. Type/Severity
.. Required Action
Notice of
Enforcement
Action
Action
- Schedulo of
Events
List of Violations
- Operation Id
- Operator Class
- Violation
¦ Type
.. Severity
¦ Enforcement Guidelines
- Violation: Action Required
Enforcement Action File
Internally Maintained Data
-------
Notice of Enforcement Action - Provides information about
enforcement action event that has occurred. It is the basis
for updating the enforcement action status log and is stored
in the appropriate enforcement action folder.
Enforcement Action Resolution - This is the final
enforcement action notice and initiates the enforcement
action closeout process.
The internally maintained information in this activity includes:
Enforcement Guidelines - These are written guidelines to
what action is required when a specific violation has
occurred. While the list is not all inclusive, it is broad
enough to allow responsive actions to be taken. The
information relates an action to a specific type of violation
with a specific severity.
Enforcement Action File - This is a hard copy file of
enforcement action folders including action notices from
initiation through completion. The information consists of
action description, date, schedule, status, and who the action
is against.
Enforcement Action Log - This is a log of all enforcement
actions including action, scheduled dates for activities,
and status.
The outputs generated by the activity include:
Enforcement Action Notice - Provides the facility operator
with a notice that an enforcement action is being taken.
Enforcement Action Schedule - Provides the schedule of
events for a prolonged enforcement action. The information
is provided to the facility operator and the enforcement
staff.
Enforcement Activity Report - Provides information, both
detail and summary, about open enforcement actions, their
status, their schedule and other pertinent information. This
report is compiled by the enforcement staff and a copy is
forwarded to the program administrator.
(8) Activity 8: Analyze Program Effectiveness
Exhibit V-10 graphically depicts the inputs, outputs, and
subactivities required to perform analysis of various aspects of
the UIC program. Activity 8 performs statistical analyses of the
UIC program to identify trends, assess the effectiveness of the
various programmatic functions, and generally to provide program
planners with information which will enable them to focus
V-l 2
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ANALYZE PROGRAM EFFECTIVENESS
SOURCE DATA SUB ACTIVITIES OUTPUT RECIPIENT
Program
Analysts
Pro gram
Support
Slaff
Program
Support
Slafl
a Program
Trends Analysis
Program
Effectiveness
Analysis
Analytical
Tallies
Program Information
- Permitting
- Inventory
- Compliance
- Enforcement
Analytical
Factors
- Objectives
- Priorities
- Weighted Factors
. . Trends
. . Effectiveness
Internally Maintained Data
Analytical Tallies
Permittee File
Operatiuns Inventory
Compliance File
Violations File
Inspection Schedule File
Enforcement Action File
Initiate Analytical
Tables
Analyze UIC Program
Trends
Analyze UIC Program
Effectiveness
-------
priorities for the next budget period. Major subactivities
include:
Initiate Analytical Tables - In order to perform the
statistical analyses, the program analyst will have to
develop analytical formulas based on program objectives,
priorities and functional goals. From these the analysts
can develop statistical factors for evaluating trends and
effectiveness. These formulas and factors will be maintained
in a series of analytical tables which can be applied to
the various analyses that will be performed.
Analyze UIC Program Trends - Using the previously developed
analytical tables, the program analysts will periodically
apply program information and perform trends analysis. From
these analyses they will identify trends from a geographic
standpoint, from an injection operation classification
standpoint, from a functional standpoint including
permitting trends, enforcement trends, compliance trends.
These trends will serve as input to program planners for
developing future program priorities and focal points.
Analyze UIC Program Effectiveness - Using the analytical
formulas and factors, the program analysts can perform
program effectiveness analyses. This is accomplished by
measuring accomplishments to date against perceived goals
and objectives by each function and the entire program. The
analyses can provide a list ranging from most effective
program area to least effective, and in this way aid program
planners in establishing priority focal points of the
program.
The inputs required by this activity includes:
Program Information - Supplied by the program support staff
this includes up-to-date information on all aspects of the
UIC program including permitting, inventory, compliance, and
enforcement.
Analytical Factors - This information is supplied by program
analysts and is the basis for the analytical tables.
Included in the analytical formula development are program
and function objectives, current priorities, and various
statistical factors relating to trend computation and
effectiveness assessment.
The internally maintained information required by this activity
includes:
Analytical Tables - These tables consist of analytical
formulas and statistical factors that will be applied in
the program analyses computations. The information is
supplied by the program analysts.
V-13
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The output information generated by this activity includes:
Program Trends Analysis - This information identifies
certain trends that the program is following both overall
and by function.
Program Effectiveness Analysis - This information identifies
how effective the overall program and the individual
functions have been through the current period.
Analytical Tables - This is the current contents of the
analytical tables. It provides the program analysts with
an opportunity to periodically reevaluate the formulas and
factors which make up the tables.
These are the activities required for an effective UIC management
information system. The feasible alternative concepts which the system
may take are described next.
2. SYSTEM DESCRIPTION
One approach for the recommended automated system is a sequential
file data storage and retrieval capability to support key UIC
inventory, permit, and violations monitoring functions. The previous
section described the activities, both manual and automated, which
comprise the UIC program administration function. This section
addresses the software components and processing capabilities of the
automated system. The system is comprised of five major functions.
Each of these is discussed in the paragraphs which follow.
(1) Permit Tracking and Inventory Maintenance
The objective of this function is to store permit application
and permittee information regarding status and permit conditions,
and operations inventory data. The system creates a Permittee
file whose primary data elements are listed in Exhibit V-ll, and
a UIC Inventory file whose data elements are listed in Exhibit
V-12. The Permit/Inventory module is an edit/update program which
reads and edits permit applications and award transactions. The
module performs basic field and range edits and produces error
lists and an error file of rejected tranactions. Accepted data
is used to update the Permittee file. When a permit is granted,
the module automatically creates a record on the Inventory file.
According to specified report selection criteria, the module
records the permit file and creates report records on a report
file. This file will be used by the report generation module to
print the requested reports.
(2) Violations and Compliance File Maintenance
The objective of this function is to track violations and
compliance actions. The module updates and accesses the
V-14
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EXHIBIT V-11
PERMITTEE DATA FILE
Permit Information Containing Key File,
Operator Identification and Location,
Operating Data, and Compliance Data
(Used By all Functional Modules)
DATA ELEMENT NAME TYPE SIZE
Key Field Data
State Code N 2
Federal Region Code N 2
Operation Identifier AN 12
Identification Data
Owner - Name AN 3 0
Owner - Address
Line 1 AN 25
Line 2 AN 25
Line 3 AN 25
Line 4 AN 25
Phone Number AN 10
Operations Data
Operation Type N 2
Operation Location
Latitude AN 7
Longitude All 7
Location Within State
County AN 10
City AN 10
Section N 2
Permit Basis N 1
Number of Wells N 4
Permit Issuance Date n 6
Permit Renewal Date N 6
Operation Status N 1
Compliance Data
Criterion
Criterion Code
Criterion Value
Max
Min
N
N
-------
EXHIBIT V-12
INVENTORY DATA FILE
Inventory of All Underground Injection Operations
DATA ELEMENT NAME TYPE SIZE
Key Field Data
State Code N 2
Federal Region Code N 2
Operation Identifier AN 12
Operation Type N 2
Identification Data
Operation Location
Latitude AN 7
Longitude AN 7
County AN 10
City AN 10
Section N 2
Permit Basis N 1
Number of Wells N 4
Operation Status N 1
Permit Date N 6
Date of Record N 6
-------
Violations and Compliance file whose primary data elements are
listed in Exhibit V-13. The module reads transactions from
inspection findings and self-monitoring reports. Basic edits are
applied to the data, error lists are generated and an error file
of requested transactions is created- Accepted data is used to
update the file. Upon request, the module will access the
Permittee file to obtain permit conditions and will compare them
to compliance data and previous compliance history to develop a
variety of exception reports. These will be used to identify
possible non-comlpiance or other problems.
(3) Federal Data Extract
The objective of this function is to provide the necessary
input to the Federal Reporting System. This is summary level
data from the Inventory, Permittee, and Violations and Compliance
files. The module reads the data bases and builds a temporary
file of selected data. The file of extracted day may be accessed
directly by the Federal Reporting System or may be used by the
Report Generator module to produce printed reports.
(4) Inspection Schedule Generation and Maintenance
The objective of this function is to provide inspection
schedules. The module uses externally developed tables of
frequency factors, and priorities, in conjunction with the
Permittee File to develop inspection schedules which are stored
in an Inspection Schedule file. Inspection schedules showing
dates, are produced. In addition, upon request the module will
scan the Violations and Compliance file which contains the
inspection results and will compare it with the inspection
schedule file to identify overdue inspection reports. The system
can also accept and incorporate unscheduled inspection
requi rements.
(5) Program Report Generator
This is a generalized reporting module which produces most
of the system reports. Accessing a report file containing records
generated by the other processing functions, the module formats
and prints hard copy reports according to report selection
parameters. In addition, the module is intended to answer ad hoc
queries. Basic structures for anticipated types of queries are
programmed in the module. Input parameters direct the actual
data selection. The module will scan the appropriate databases
for necessary information and structure the requested report. It
must be noted that this is not a totally generalized reporting
capability, but represents a set of report types for which
parameters can be supplied to dictate data selection.
(6) System Processing
V-15
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EXHIBIT V-13
VIOLATIONS AND COMPLIANCE DATA FILE
History of Violations and Compliance
DATA ELEMENT NAME TYPE SIZE
Key Field Data
State Code N 2
Federal Region Code N 2
Operation Identifier AN 12
Operation Type N 2
Violation History Data
Violation Type N 1
Violation Date N 6
Violation Severity N 1
Correction Status N 2
Date Corrected N 6
Detection Mechanism N 1
Enforcement Action
Identification AN 4
Compliance Data
Self-Monitoring
Report Date N 6
Violation Status A 1
Criteria Violated N 2
Value Reported N 5
Inspection
Report Date N 6
Violation Status A 1
Criteria Violated N 2
Value Reported N 5
-------
A variety of processing cycles apply to different system
functions. Monthly processing will include updates to the
Permittee file with applications, permits, and permit
modifications. Entry of granted permits automatically triggers
an Inventory file update. Overdue applications reports will be
produced. Inspection from transactions will also be entered on
a monthly basis. Following update the inspection schedule and
compliance file will be scanned to detect overdue inspection
reports.
Self-monitoring reports will be received and entered on a
quarterly basis. Following the update, exceptions will be
reported. Annual processing includes generation of an inspection
schedule for the coming year. The Federal Reporting System
Extract file will be generated annually. Ad hoc or irregular
cycles will accommodate entry of unscheduled inspections, and
requests for reports.
3. IMPLEMENTATION PLAN
This section presents a plan for implementation of the recommended
system concepts. The plan presents major steps, timing, and key
considerations. The system implementation is comprised of three major
phases:
System design and development
Regional pilot implementation
Full implementation start up.
Exhibit V-14 provides a schedule for the major steps. Each of the
phases is dicussed in the paragraphs which follow.
(1) System Design and Development
The steps required to design and develop the recommended
system concept are described below. We recommend that the Working
Group including representatives of ODW, MIDSD, the Regions, and
the States be used to guide this process. System design for the
UIC information system is expected to occur in two phases. This
two-phased approach is the direct result of the evolving
regulatory environment of the UIC program. The first phase
immediately follows the feasibility study and approval of the
recommended system concept. The Phase I design called a general
design on the Exhibit, will address the detailed logic, data
elements, file structures, and processing controls which can be
established on the basis of current knowledge and regulations.
The design will be submitted for Working Group review so that it
reflects consensus at that point. There will be a delay then,
until the regulations are promulgated.
V-16
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UIC MANAGEMENT INFORMATION SYSTEM
IMPLEMENTATION PLAN
MAJOR STEPS
Jun Jul Aug Sep Oct Nov Dec
1979
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
'*0
Jan
\
Oct
SYSTEM DESIGN AND DEVELOPMENT
o General Design
o Detailed Design
o Program Specifications, Code and Test
o Support Procedures Development
REGIONAL PILOT IMPLEMENTATION
o Training
o Data Conversion
a Prototype Operation
a Implementation Evaluation
FULL IMPLEMENTATION START UP
~
X
X
<
-------
Upon promulgation of the regulations, detailed design
activity will resume. Depending upon the nature and extent o£
changes to the regulations since completion of the generation
design, some additional requirements analysis may be conducted.
The design will be updated and all necessary detail provided.
Program specifications development will commence followed by
coding and testing. Support procedures which address manual
handling of UIC data will be developed concurrently with automated
system development. Based on assumptions regarding regulations
promulgation and the extent of the changes to the design, the
exhibit shows an operational system by June of 1979. Brief
descriptions of the major design and development steps are
provided below.
Perform Detailed System Design
Having developed a system concept, the next step is to
crystalize that concept into an operational system. A
detailed system design is the mechanism for making the
transition from a system concept to an operational system.
From the system concept evolves the hardware requirements,
and a master system flow. The detailed design effort
consists of defining the data files and the system modules,
developing specifications for each program and developing
a system implementation plan. Thus, the detailed system
design step consists of a series of separate tasks. These
tasks are:
Define the Systems Data Files
The purpose of this step is to fully define the system
files which will be used by the modules of the system.
These files have previously been identified in the
system concept. The task involves defining each
individual data element in terms of characteristic,
size, and location within the record. Additionally,
the record characteristics and file access method must
be determined.
To assist in the documentation and maintenance of the
system data files, we recommend development of a Data
Element Dictionary for the system. The Data Element
Dictionary is a means of identifying and defining the
characteristics and location of the data elements
contained within the system.
Define System Modules
Having fully defined the data files of the system, the
next required task is to define the individual
processing modules that make up the overall system.
Using the master system flow developed in the system
V-l 7
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concept along with the system requirements and data
files, we can determine the logical modules that will
make up the system. These modules are then further
grouped into programs and finally each program is
assigned the function it will perform. When this is
complete, the next task is to develop individual program
spec i f icat ions.
Develop Program Specifications
At this point in the detailed design, we have defined
the data requirements and the system modules for the
system. We have also identified each program in the
system and its function. We now must prepare individual
specifications of each program. It is from these
specifications that the programmers will write the
programs. Specifications include input to the program,
logical processes and output of the program.
Establish Implementation Plan
At the same time that the program specifications are
being developed, the plans for implementing the system
must be prepared. This effort includes the following
activities :
Identify system implementation tasks
Determine time-phased system testing pattern
Identify manpower requirements necessary to
implement, and break down implementation steps to
the individual task level.
Prepare system implementation document for
distribution to personnel involved.
This task is the final task in the detailed system design
step.
Programming and Test
This step in the implementation plan consists of coding the
individual programs to the assigned specifications. This
programming effort includes writing the programs, compiling
them and initially testing each program to assure it is
doing what it is required to do. This initial testing of
the programs usually involves the creation of test data
which should reflect the live data that the system will
process. It is during the initial unit testing of each
program that test files are created. These files should
reflect the characteristics required of the live data files.
V-l 8
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An added test phase in this instance is the module test of
the programs. These tests may involve several programs which
comprise a module and they should be tested together to
determine if the module is performing correctly. Finally,
a system test will be conducted according to the test plan
developed earlier. The objective is to assure that all
functions operate properly in concert.
Develop Support Procedures
This step consists of the assembly, organization and
documentation of all information describing the interaction
of the user with the system. This involves the preparation
of system and program documentation. In addition, user
manuals for the various user/system interface points are
prepared. Finally, system operating documentation is
prepared for the run streams and parameter set-ups. This
step is done in parallel to the programming and unit test
step.
(2) Regional Pilot Implementation
Although the system is expected to be operational by early
June 1979, program activity in the form of Federal permit issuance
and tracking, and self-monitoring reports is not expected to begin
until about October 1980. In the interim, it is desirable to
implement the system in one Region as a prototype. This pilot
implementation will serve the purposes of:
Ensuring operational status of the system
Testing manual procedures and training techniques
Developing an experience base for future implementation.
The Region selected must be able to obtain data from a cooperating
State that intends to use the EPA UIC system for program
administration. If at all possible, the State should already have
a UIC program, and must be prepared for the Federal reporting
requirements to be imposed on the generators. The implementation
will then proceed through training, data conversion, prototype
operation, and implementation evaluation. Each of these steps is
described briefly below.
Training
This step consists of training data entry clerks, senior
analysts, supervisors, and senior ADP personnel from the
Regional Office in the procedures for entering, analyzing
and correcting data for the system. The training will be
conducted at the Regional Office by members of the contractor
staff.
V-19
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Data Conversion
Inventory data provided by the cooperating State will be
enetered in the system. This activity involves reformatting
the data as necessary and then loading it to the UIC
inventory file. Reformatting may be a manual procedure if
the state inventory files are not automated; or it may
involve developing a translation routine to read automated
State files and write the data in UIC file format.
Prototype Operations
Operators in the cooperating State will submit self-
monitoring reports and Federal permit applications. These
will be entered into the system according to established
procedures. Inspection schedules will be developed and
initial inspections made. In short, production operation
will begin for the selected State program. All reports
produced by the system will be carefully checked and file
samples will be taken to ensure that the system is operating
properly.
Implementation Evaluation
After the system has been operating for several months, an
evaluation of the implementation will be made. The objective
is to identify any system on procedural weaknesses, identify
training techniques which need improvement, and assess the
efficiency of the data conversion operation. Findings will
be analyzed to determine what improvements need to be made
prior to further implementation.
(3) Full Implementation Start-Up
At such an early stage it is not possible to determine the
sequence of events for full scale implementation of the system.
However, some factors which must be considered when planning the
implementation can be discussed such as:
Limiting concurring activity in one Region
Integrating training where possible
Balancing manual data conversion with automated conversio.
Phasing in the automated capabilities of the system.
A likely scenario is a Region with two States wishing to
use the EPA system for their own program and two or three States
whose programs will be administered by the Region. It is important
to limit the amount of concurrent activity in the Region to avoid
confusion. Although in a centralized system the State will be
V-20
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accessing the system directly, the Regional staff may well be
called upon to help if problems arise due to their proximity.
Therefore, it is necessary that a Region be aware of the timetable
for all of its States with regard to the system and to plan its
activities accordingly.
Another area where planning is needed is the training phase.
It is certainly more efficient if all expected users of the system
in a regional area can attend the same training session. However,
if training is conducted at a time too far from actual system
generation, it is largely wasted. Again, plans should be carefully
reviewed and where sharing can be accomplished, group training
sessions would be conducted.
The data conversion process will probably be the most
demanding implementation activity. Some States will have
automated data and some will not. In planning to implement several
non-primacy States, the Region should consider whether data
conversion is manual or automated. Even if manual conversion is
performed by a contractor, there will be management
responsibilities, quality assurance checking, and error handling
which must be handled by the Region, it is suggested that only
one manual conversion be attempted at a time. This could be
paralleled by an automated conversion, if the automated conversion
requires only a straightforward automated conversion program.
When the system is ready to be implemented at all selected
sites, there will be a need to be able to manage and control the
start-up operation. One way of accommodating effective management
and control is to gradually phase in the automation capabilities.
The system is somewhat unique in that it is designed in such a
way that the various automated modules are for the most part
independent of one another. In this way, it is feasible to
initially bring up the Permit Tracking and Inventory Maintenance
module at the outset so as to maintain the required inventory
permit data. Then the additional automation capabilities such
as Inspection Scheduling, Compliance Screening and File
Maintenance and Special Inquiry would be gradually phased in, so
that when the initial implementation and start-up is complete at
all sites the system will be operating to its full capacity.
4. UIC FEDERAL REPORTING SYSTEM
The UIC management information system that has been discussed is
a system designed to support the program administration level. Current
EPA regulations require submission of an annual report to the Agency
by the program administering entities. This information will be
provided from the data maintained in the UIC system. The repository
of the incoming summary level information will be a Federal reporting
system for UIC summary data. This UIC Federal Reporting System will
be capable of generating the annual report, updating the National
Inventory and maintaining summary information for other aspects of
the UIC program such as permitting, violations and enforcement.
V-21
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(1) System Descriptions
Exhibit V-15 graphically depicts the inputs, major
activities, and outputs of the UIC Federal Reporting System. The
primary function of the UIC Federal Reporting System is to support
the information requirements of EPA Headquarters as imposed by
the regulations, and as needed in its role of national program
management. The major activities required by the system to
support this function include:
Aggregate Program Summary Data - On an annual basis, the UIC
Federal Reporting System will receive summary level
information from the UIC program administering entities.
This information will include inventory, permitting,
violations and enforcement actions data. This incoming data
from the programs will be aggregated into a series of
national totals for inclusion in the Annual Report and for
file updates.
Update National Inventory - Included among the incoming data
are summaries pertaining to adjustments of the individual
State inventories. When aggregated, these totals will be
used to update the count in the National UIC Operations
Inventory. These adjustments include additions, deletions,
temporary status changes due to permit revocations or
shutdowns pending compliance with regulations. The product
of this activity is a current annual national inventory of
UIC operations.
Update National Program Totals - In addition to the summary
or inventory adjustments, the aggregated information
includes summaries of permit activity, violations and
enforcement actions. This information will update the UIC
Federal Reporting System data base which maintains program
summaries by activity.
Prepare Annual Report - By regulation, the program
administering entities are required to report annually to
EPA on the status of their program and the activity of the
past year. The UIC Federal Reporting System will incorporate
this information into an overall National Program Annual
Report for the Agency.
Prepare Management Reports - In addition to the Annual
Report, the UIC Federal Reporting System will be capable of
generating various national program management reports.
These reports will serve to inform management of program
effectiveness during the past year.
Respond to Inquiries - In addition to the program management
reports which are for internal Agency use, and the Annual
Report which is intended for both Agency and external
V-2 2
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UIC FEDERAL REPORTING SYSTEM
FUNCTIONAL DESCRIPTION
SOURCE DATA ACTIVITIES OUTPUT RECIPIENT
¦ UIC Program
Annual Report
ln<|uiry Response
Request for
Information
UIC
Proyram
Administration
Level
Information
Requests
- Conyress
- Interest Groups
- Public
- Federal Ayencies
a Information
Requestors
- Conyress
- Interest Groups
- Public
Inventory
Adjustments
Permit Summary
- Issuances
- Revocations
Violations Summary
Enforcement
Action Summary
Internally Maintained Data
National Inventory
National Violations Summary
National Permit Activity
Summary
National Enforcement
Actions Summary
Aggregate Proyram
Summary Oata
Update National
Inventory Totals
Update National
Program Totals
Prepare Annual
Report
Prepare Management
Reports
Respond to Inquiries
-------
viewing, the UIC Federal Reporting System will have the
capability to respond to information requests from external
sources such as Congress, special interest groups, and the
general public.
Input required to support the major activities includes:
Inventory Adjustments - This information is required to
maintain a current National UIC Operations Inventory.
Included in this information are additions to the inventory
to reflect new permitted facilities, deletions to the
inventory to reflect operations which are abandoned, plugged,
or permanently shut down, and status changes to existing
inventory items such as temporary shut-down, suspension or
permit revocation.
Activity Summaries - This information includes past year
activity totals Eo~r permitting, violations, and enforcement
actions. This information is used to prepare the National
program management reports for EPA Headquarters.
Request for Information - It is anticipated that EPA
Headquarters will receive requests for information
concerning various aspects of the UIC program. These
requests will most likely come from Congress, special
interest groups, and the public. The information requested
is likely to be of a summary nature, such as number of
permitted facilities, number of violations, and other types
of information.
The internally maintained information for the UIC Federal
Reporting System will include:
National Inventory - The inventory of UIC operations will
consist of minimal information for each operation. The
information will include operation totals by classification
and location. They will also include operational status
totals.
National Violations Summary - This information includes
totals by type of violation, total violations by location,
and total violations by operation classification.
National Permit Activity Summary - This includes total
permits issued, suspended, revoked and denied. Each set of
totals will be by operation classification and location.
National Enforcement Actions Summary - This includes
information on the enforcement actions taken over the past
year. These totals are maintained by type of action, location
of action and operation classification.
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The
output generated by this system includes:
UIC Program Annual Report - This report contains a summary
oT the past year's nationwide activities in the areas of
inventory, permitting, violations, and enforcement actions.
It is prepared for internal Agency distribution as well as
public information to interested parties.
UIC Management Reports - These are a series of reports by
activity which enable the cognizant Headquarters staff to
ascertain the effectiveness of the activity from a national
perspective.
Inquiry Response - These contain information related to the
national UIC program, which has been requested by various
parties.
(2) System Considerations
In developing the concept for a UIC Federal Reporting System,
we focused on the information requirements of EPA Headquarters.
These requirements were both required by the regulations and
identified as being necessary by EPA staff involved in the UIC
programs. The concept presented satisfies these information
requirements.
Within the framework of this study of feasible alternatives
for a UIC management information system for the program
administrative level, we identified the system activities
required by a system supporting the National program oversight
function. These activities, as depicted in Exhibit III-6, are
easily automated in their entirety. Therefore, we feel that the
UIC Federal Reporting System should be a totally automated system,
resident at an EPA national data center.
Finally, in order to be responsive to both administering
entities and monitoring Regions which receive only summary data
from primacy states, the UIC Federal Reporting System should be
configured to accept a summary data file from the UIC management
information system.
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