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         U.S. ENVIRONMENTAL PROTECTION AGENCY
         OFFICE OF INSPECTOR GENERAL

                            Catalyst for Improving the Environment
Briefing Report
       ECHO Data Quality Audit - Phase I
       Results:  The Integrated Compliance
       Information System Needs Security
       Controls  to Protect Significant
       Non-Compliance Data
       Report No. 09-P-0226

       August 31, 2009

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Abbreviations

DMR        Discharge Monitoring Report
ECHO       Enforcement and Compliance History Online
EPA         U.S. Environmental Protection Agency
ICIS         Integrated Compliance Information System
IDEA        Integrated Data for Enforcement Analysis
NPDES      National Pollutant Discharge Elimination System
OECA       Office of Enforcement and Compliance Assurance
OIG         Office of Inspector General
PCS         Permit Compliance System
SNC         Significant Non-Compliance

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      PRtf
U.S. Environmental Protection Agency
Office of Inspector General

At  a  Glance
                                                                                         09-P-0226
                                                                                     August 31, 2009
                                                               Catalyst for Improving the Environment
Why We Did This Review

This review, conducted by
KPMG, LLP, on behalf of the
Office of Inspector General,
sought to evaluate the quality and
integrity of data that resides in
the U.S. Environmental
Protection Agency's (EPA's)
Enforcement and Compliance
History Online (ECHO) system.

Background

ECHO provides integrated
compliance and enforcement
information for approximately
800,000 regulated facilities
nationwide.  ECHO allows users
to find inspection, violation,
enforcement action, informal
enforcement action, and penalty
information about facilities for
the past 3 years. ECHO contains
information for the facilities
regulated under the following
environmental statutes: Clean
Air Act Stationary Source
Program, Clean Water Act
National Pollutant Discharge
Elimination System, and
Resource Conservation and
Recovery Act.
For further information,
contact our Office of
Congressional, Public Affairs and
Management at (202) 566-2391.

To view the full report,
click on the following link:
www.epa.gov/oig/reports/2009/
20090831-09-P-0226.pdf
              ECHO Data Quality Audit-Phase I Results:
              The Integrated Compliance Information System
              Needs Security Controls to Protect Significant
              Non-Compliance Data

               What KPMG Found
              End users of the Permit Compliance System and Integrated Compliance
              Information System National Pollutant Discharge Elimination System
              (ICIS-NPDES) can override the Significant Non-Compliance (SNC) data field
              without additional access controls. This occurs because EPA has not
              implemented database security features to restrict access to this field. Further,
              the ICIS-NPDES database edit checks do not prevent access to the SNC field.
              As a result, users can change original data without authorization, which could
              directly affect ICIS-NPDES data made available to the public via ECHO.

              Other than the above weakness, KPMG noted that EPA implemented many
              effective processes designed to populate the Integrated Data for Enforcement
              Analysis (IDEA) database, which the ECHO system uses to create reports for
              its users. KPMG noted that many of the EPA systems that feed data to IDEA
              have front-end edit checks designed to help ensure data quality. Further,
              KPMG noted that making data available through ECHO is a very complex
              process that involves many data systems. KPMG noted that EPA has
              developed a methodology to manage the States' data conversions. KPMG
              noted that EPA's data mapping and system  life-cycle documentation, data
              migration tools, and lessons learned processes are effective in managing this
              complex data conversion process.
               What KPMG Recommends
              The Director, Office of Compliance, Office of Enforcement and Compliance
              Assurance (OECA), should implement database security features to limit the
              end users' ability to change the SNC code in ICIS-NPDES.

              On August 6, 2009, the EPA Office of Inspector General met with OECA to
              provide a briefing report of KPMG's work to date and discuss the SNC code
              finding.  OECA provided informal comments on the finding. OECA plans to
              explore additional options to restrict manual SNC code override in
              ICIS-NPDES.

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  WASHINGTON, D.C. 20460
                                                                          OFFICE OF
                                                                       INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
                                   August 31,2009
                    ECHO Data Quality Audit - Phase I Results:
                    The Integrated Compliance Information System Needs
                    Security Controls to Protect Significant Non-Compliance Data
                    Report No. 09-P-0226
                    PHI*™*     ,
                    Rudolph M. Brevard
                    Director, Information Resources Management Assessments
                    Office of Mission Systems

                    Cynthia Giles
                    Assistant Administrator
                    Office of Enforcement and Compliance Assurance
Attached is the briefing report for the first phase of the data quality audit of the Enforcement and
Compliance History Online system. KPMG, LLP, conducted this audit on behalf of the Office of
Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA). This report
contains findings that describe the problems KPMG identified and corrective actions KPMG
recommends.  This report represents the opinion of KPMG and does not necessarily represent the
final EPA position.  Final determinations on matters in this report will be made by EPA
managers in accordance with established audit resolution procedures.

KPMG conducted this portion of the audit from July 2008 to June 2009 at EPA Headquarters in
Washington, DC, in accordance with generally accepted government auditing standards issued
by the Comptroller General of the United States. These standards require planning and
performing the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for
findings and conclusions. KPMG believes that the evidence obtained provides a reasonable basis
for the findings and recommendations.

Action Required

In accordance with EPA Manual 2750, you are required to provide a written response to this
report. We are requesting your response within 90 calendar days. You should include a
corrective actions plan for agreed upon actions, including milestone dates.

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We would like to thank your staff for their cooperation. We have no objections to the further
release of this report to the public. This report will be available at http://www.epa. gov/oig.

If you or your staff has any questions regarding this report, please contact me at (202) 566-0893
or brevard.rudy@epa.gov; or Harry Kaplan, Project Manager, at (202) 566-0898 or
kaplan.harry@epa.gov.
cc:
Lisa C. Lund
Gwendolyn Spriggs

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Briefing Report
ECHO Data Quality Audit - Phase I
Results: The Integrated Compliance
Information System Needs Security
Controls to Protect Significant Non-
Compliance Data

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ECHO Data Quality Audit
Phase I - Results
   Objective and Scope
   Progress To Date
   Planned Tasks
   Observations and Recommendations
   Questions & Answers
                           -1-

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ECHO Data Quality Audit
Phase I - Results
 The overall audit objective is to evaluate the processes and controls
 used to support the quality of data that is ultimately presented
 through Enforcement Compliance History Online (ECHO) system
 queries.

 The audit scope includes two phases:
  +  Phase I -- Data integrity review of processes and controls used to
     populate the Integrated Data for Enforcement Analysis (IDEA)
  +  Phase II -- Data quality processes and controls for select source
     systems that feed IDEA

 We selected and reviewed the Permit Compliance System (PCS) and Integrate
 Compliance Information System National Pollutant Discharge Elimination
 System (ICIS-NPDES) as the source systems for this project.
                              -2-

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ECHO Data Quality Audit
Phase I - Results
                      nut
   We have conducted meetings with officials from:
    >  Office of Enforcement and Compliance Assurance
    >  Office of Environmental Information
    >  Veterans Affairs Office of Inspector General to discuss
       system mainframe controls
    >  State of Georgia to discuss ICIS-NPDES
    >  Region IV to discuss PCS and ICIS-NPDES
                            -3-

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ECHO Data Quality Audit
Phase I - Results
  We have gained an understanding of the process used to
  populate IDEA and ECHO.

  We have gained an understanding of the PCS and ICIS-
  NPDES data elements and related data quality processes.

  We have gained an understanding of the State conversion
  process from PCS to ICIS-NPDES.
                           -4-

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ECHO Data Quality Audit
Phase I - Results
   Perform testing of key PCS and ICIS-NPDES business rules to
   validate data logic.

   Trace a sample of PCS and ICIS-NPDES data elements into IDEA
   to test IDEA data quality.

   Review select supporting source documentation (e.g., DMRs)
   supporting PCS and ICIS-NPDES, and ultimately IDEA.

   Review select PCS and ICIS-NPDES controls over data field
   security.

   Test controls over the conversion process from PCS to ICIS-
   NPDES
                            -5-

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ECHO Data Quality Audit
Phase I - Results
                                 [•71   II^Jli
   Observation #1:

   EPA appears to have effective processes designed to populate
   IDEA from the source systems.
                            -6-

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ECHO Data Quality Audit
Phase I - Results
                                  [•71  II^Jli
    Observation #2:

    With such a large and complex data conversion, EPA has
    developed a methodology for the States conversion process
    that includes mapping documentation, system development
    life-cycle documentation, migration tools, and a lessons
    learned process after each state conversion that is used to
    update the methodology for future conversions.

    Some key parts of this process
    >  Workgroup meeting and conference calls;
    >  Test runs for the data conversion;
    >  Data element mapping from PCS to ICIS-NPDES
                             -7-

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ECHO Data Quality Audit
Phase I - Results
   Observation #3:

   ICIS-NPDES has front end edit checks designed to help ensure
   data quality. For example, we noted that ICIS-NPDES provides
   warnings if DMR data exceeds authorized limits. Note that we
   have not yet tested the full effectiveness of the edit check
   controls.
                            -8-

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ECHO Data Quality Audit
Phase I - Results
   Observation #3: (Continued)

   During our ICIS-NPDES demonstration that the Georgia data
   steward showed us, there appears to be strong front end edit
   checks that are designed to ensure data quality. The data
   steward told us that the new screen layout made data entry
   "user friendly" and more intuitive

   Information from the DMR is the source for information entered
   into ICIS-NPDES.

   When data is entered into the data field, it is checked to  ensure
   it is the correct data type (i.e. alpha, numeric). If the correct
   data type is not entered the data entry clerk will be alerted to
   this when they move to the next field.
                             -9-

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ECHO Data Quality Audit
Phase I - Results
   Observation #3: (Continued)

   If the DMR amount is greater than the permit amount allowed, a
   warning screen informs the data entry clerk that the amount
   exceeds the limit. At this point the data entry clerk will then
   review the input and if a correction is needed will make the
   correction and if nothing is required will continue with data
   entry.
                            -10-

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ECHO Data Quality Audit
Phase I - Results
   Observation #4:

   End users can override the ICIS-NPDES Significant Non-
   Compliance (SNC) data field without additional access controls.
   There are compensating detective controls, such as audit trails
   that document who changed the SNC field, however, these are
   only effective if the audit logs are actively reviewed on a regular
   basis.

   Management has not fully implemented database security
   features to restrict access to this field to authorized users.
   ICIS-NPDES also does not have any business rules to prevent
   this from happening.
                            -11-

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ECHO Data Quality Audit
Phase I - Results
   Observation #4: (Continued)

   The lack of a preventative control around the SNC data field
   allows users to change original data without authorization that
   could directly impact the data quality of this element in ICIS-
   NPDES which are then passed onto Integrated Data for
   Enforcement Analysis (IDEA) and ECHO.

  Recommendation: The Director, Office of Compliance
  should:

  1.  Implement ICIS database security features to limit the end
     users' ability to change the SNC code.
                            -12-

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