Integrated Compliance Information System (ICIS) and the Exchange Network

David A. Hindin, DirectorEnforcement Targeting and Data DivisionOffice of ComplianceOffice of Enforcement and Compliance Assurance

Exchange Network National MeetingNashville, TN, April 30, 2008

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Purpose

Review ICIS-NPDES (PCS Modernization) phased approach, with emphasis on Exchange Network Flows.

Status of Alternative Analysis for ICIS-NPDES full batch.

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ICIS Phased Approach

Implemented FY 2002

Replaced 3 outdated national systems and several regional tracking systems.Integrates with FRS. Used by HQ and Regions to manage enforcement and compliance. Supports annual results public reporting, such as GPRA pounds of pollutants reduced.

Modernization of the CAA Air Facility System – (AFS)

AFS tracks permit compliance and enforcement data for major stationary sources.

FY2008: DevelopingBusiness requirements

Direct Users

Implemented FY 2006

• 21 States• 2 Tribes• 9 Territories

More recentprogram requirements• CAFO• Storm water• CSO• SSO

Batch ReleasePart 1Hybrid Users

May 5, 2008Implement 1State

August 2008 Implement 4 to 6States.

FY09: Implement 2 to 4 states

Direct entry of all data except DMR data, which will be electronically transferred.

Batch Release Part 2NetDMR

Aug 2008:“demonstrable”done perGrant.

FY09:Testing andImplement Permittees electronicallysign & submit DMRs.

Batch ReleasePart 3Full Batch

Begin workFY 2009

For 22 States to electronicallytransfer all their data from their state system.

May be revisedbased on AlternativeAnalysis

National Pollutant Discharge Elimination SystemNPDES

Phase II: PCS Modernization

Federal Enforcement and Compliance

Phase IEnforcement Docket

Clean Air ActStationary Sources

Phase IIIAFS Modernization

Exchange Network

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Logic of the 3 Part ICIS-NPDES Batch Approach

Part 1 for DMR hybrid states provides the basic infrastructure and functionality for batch data exchanges between state NPDES information system and ICIS-NPDES using the Exchange Network.

Part 2 for NetDMR uses Part 1 functionality and expands upon it. There are three ways a state may use NetDMR:1. State Locally Hosts NetDMR Using the ICIS-NPDES Data Flows Via

the Exchange Network.2. State Uses U.S. EPA Hosted and Maintained NetDMR (federal

instance). (Assumes state is in ICIS-NPDES and not PCS.)3. State Adopts NetDMR to Connect Directly to State NPDES Information

System.– The next presentation by Brandon Harris will provide more information

on NetDMR.

Part 3 for Full Batch is designed to use functionality from Parts 1 and 2 and then builds intelligence to process all data families.

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ICIS-NPDES Batch DMR Part 1 Key Milestones

October 2006: Initiated the ICIS-NPDES (PCS Modernization) Batch Integrated Project Team (IPT),

Participants include staff and managers from 26 states, 6 regions, EPA/OECA and EPA/OEI.

Support the development and testing of the ICIS-NPDES DMR batch release. Conducted monthly conference calls of the IPT.

November 2007: Completed functional, integration and load testing with CDX. March 2008: Completed User Validation (real data flowing from Illinois via

CDX to ICIS-NPDES) and Acceptance Testing, and DMR Schema Approved by ICIS IPT.

April 18, 2008: ICIS-NPDES XML schema and associated documents for DMR data family approved by Exchange Network NTG.

May 5, 2008: Implementation for Hybrid Pilot State: Illinois will move from PCS to ICIS-NPDES, with batch DMR flows in operation.

August 2008: Implementation for 4 to 6 hybrid States. Spring 2009: Implementation 2 to 4 hybrid states.

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

CDX/Exchange Network

Node services(including NAAS, node archive, virus check, schema validation)

State Node

State User

Pre-Process

ICIS Batch Processing

NPDES Data

1. Authenticate

2. Submit

3.Process

4.Submit

5. Process Batch

6. Authenticate

8.Notify

ICISBatch Node

7.Submit

9. Authenticate10. getStatus

11. Download

Firewall

Firewall

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ICIS Hybrid Batch Submission Process

XML data

errors?

State generates and

zips XMLs XML file

errors?

XML files virus

free and valid?

State NPDES System

State Uploads to CDX manually

State electronic

ally submits to

CDX via Node

CDX sends XMLs to

ICIS

ICIS Batch parses XMLs

ICIS Batch saves data in ICIS-NPDES

ICIS Batch sets status to “Completed” and sends PDF to CDX

ICIS Batch logs errors

CDX logs first 100 errors and sets status

to “Failed”

State user

views status

and errors

on CDX web form

State node gets status

and downloads errors from

CDX

State views batch accepted, rejected, summary reports in

ICIS

ICIS done

parsing?

Yes

Yes

Yes

Yes

No

No

No

No

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ICIS Hybrid Batch Submission Process State or NetDMR generates XML file, zips it up, and submits it to CDX

Manual upload using a CDX web page Automated upload using State or CDX Node (recommended)

CDX performs a virus scan of the file and validates all XMLs against the ICIS schema Infected or invaild XMLs rejected as SOAP messages and status is set to “Failed” External Batch ID is assigned for tracking purposes Clean and valid XMLs forwarded to ICIS Batch and a copy is archived

ICIS Batch receives XMLs and processes them Rejects entire XML if ICIS ID is invalid or unexpected errors occur during processing Rejects one record within an XML if ICIS ID has “read rights” only, invalid transaction,

missing key data, or erroneous data Saves each record into ICIS tables if no errors Creates PDF of results when batch is processed Notifies CDX to set status to “Completed”

State Nodes retrieve status and download the PDF or results when status is “Completed” or “Failed”

CDX web page submitters view status and download the PDF or results from Transaction History page

Hybrid users log into ICIS to see ICIS Batch Accepted Transactions, Rejected Transactions with errors and Audit Report

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ICIS Batch XML Transactions

ICIS parses XML files to extract individual payloads ICIS orders payloads within batch

Based on Submission Type and Transaction Type Similar to processing order followed by PCS Transaction types vary based on data family.

Five transactions types have been designed for ICIS batch that direct how the system will accept a data submission. Three of these, for the DMR data family, have been built and will be in production in May 2008.

Mass Delete Allows the user to blank out all data for an existing record along with data or links to data

associated with it. Change

Allows the user to submit specific field changes to data in ICIS. Replace

Allows the user to submit blanket changes to data in ICIS by changing fields that have a tag and blanking out fields that are missing tags (targeted replacement, not full replacement)

Delete Allows the user to blank out all data for an existing record only if it has no data associated

with it. New

Allows the user to add a new record to ICIS.

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Three Transactions Types for DMRs

Mass Delete (X) Allows the user to blank out all data for an existing scheduled DMR Form. Allows the user to remove an entire unscheduled DMR Form. Records an accepted or rejected transaction for each parameter and the Auxiliary

Data.

Change (C) Allows the user to submit specific changes to the DMR data in ICIS. ICIS only updates the fields specified in the XML. Records an accepted or rejected transaction for each parameter that the XML

attempts to update.

Replace (D) Allows the user to submit DMR data to ICIS without considering the current state of

received DMR data in ICIS. ICIS replaces all of the existing data for each of the parameters submitted in the XML. Records an accepted or rejected transaction for each parameter that the XML

attempts to update.

These transaction types were developed with the participation of the Integrated Project Team and are fully explained in the ICIS-NPDES XML Schema User’s Guide, Version 1.5 – For DMR Batch, March 7, 2008.

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ICIS Hybrid Batch Audit Reports ICIS Batch Audit Reports are available to DMR Hybrid states within the Business Objects module of the ICIS online system:

Accepted Transaction Report Provides list of transactions that were accepted

Rejected Transaction Report Provides list of transactions that were rejected with the key fields of the record and a message explaining why

Transaction Summary Report Provides counts of accepted and rejected transactions by data family. Provides success rate

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ICIS Hybrid Batch Error and Warning Messages

Error Messages Whenever CDX cannot properly validate a CDX user, encounters an infected

submission or finds an invalid XML file, up to 100 error messages are produced. Whenever ICIS rejects a transaction, one or many error messages are produced

to identify the problem. CDX error messages are presented in SOAP messages which can be returned

to a State Node or displayed on the CDX web login or ICIS upload screen ICIS error messages are presented on the Rejected Transactions Audit Report,

which can be accessed through the ICIS web interface, downloaded by a State Node, or displayed on the CDX web transaction history screen.

Warning Messages Warning messages indicate that a transaction has been accepted, but there is

important information that the user should know about. Warning messages are presented on the Accepted Transactions Audit Report,

which can be accessed through the ICIS web interface.

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Alternative Analysis In accordance with the Office of Management and Budget (OMB) requirements, all

federal agencies must periodically conduct an Alternative Analysis of their large information systems to evaluate the benefits and costs of the current systems (the status quo) in achieving the business need, and compare this to three alternative approaches for meeting the same business need.

EPA’s Office of Enforcement and Compliance Assurance (OECA) must complete an Alternative Analysis for ICIS in FY2008. While the Alternative Analysis is focusing on the full batch release, it will include all of ICIS (such as AFS Modernization).

EPA contracted with SRA International, Inc. to conduct the Alternative Analysis.

EPA is including state input in the Alternative Analysis process. EPA believes this input could help:

Improve the currently planned technical approach for completing PCS modernization via ICIS-NPDES full batch;

Improve the identification and evaluation of alternative technical approaches for completing PCS Modernization for the full batch states.

(In a separate process, EPA also solicited input from the direct user states on their experiences in using ICIS-NPDES.)

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First Round of State Input: January and February 2008

EPA Conducted teleconferences with ICIS Batch states to explain current design for ICIS Full Batch.

SRA conducted full day meetings in DC, Denver and Atlanta with states to solicit concerns with the current planned technical approach for and identify new approaches 20 states participated, plus Exchange Network representatives, ICIS

staff, OIE Staff, and several EPA regions. States were given time to develop high level proposals on alternatives to ICIS full batch

Proposals were presented to EPA and state representatives to gather feedback and refine ideas.

States submitted additional information on alternative designs via written comments 11 comments were received from 12 states.

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SRA Initial Alternatives Identification SRA evaluated state input from round 1. In addition to evaluating state input, SRA surveyed design patterns for

architectures different from EPA or State designs SRA looked at designs from other systems at EPA SRS looked at systems in production at other agencies (e.g. Pension

Benefits Guaranty Corporation, Corporation for Public Broadcasting) SRA reviewed literature on system designs for similar systems available to

the general public SRA proposed 2 new alternative designs for a total of 8 discrete alternatives

for consideration (1 EPA, 5 State, 2 SRA) SRA detailed all 8 alternatives and highlighted pros and cons of each After additional analysis, SRA recommended elimination of three of the

eight alternatives Results were presented to, and accepted by EPA’s ICIS Senior

Review Group. This narrowed the alternatives from eight to five.

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Second Round of State Review

Eight alternatives, showing the three dropped, were shared with states on March 28 and presented in conference call on April 7.

Four states also submitted written comments.

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Summary of Alternatives

Proposed AlternativesAlternative 1 - Current EPA Design (Fine Grained Transactions)Alternative 2 - Coarse Grained TransactionsAlternative 3 - Full Data WarehouseAlternative 4 - Summary Data Warehouse (Eliminated)Alternative 5 - PCS Data Conversion (Eliminated)Alternative 6 - ICIS State (Eliminated)Alternative 7 - Web Service BusAlternative 8 - Data Queue

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Next Steps We are in the process of narrowing down the five alternatives to three. This

decision is expected to be made soon. There will be a Third Round of State input.

In early May, EPA will distribute the three alternatives selected for full evaluation to the states.

SRA will conduct a web conference call with states to discuss the three alternatives on May 21.

States may submit written comments on the three alternatives by May 30. Results of Mississippi mapping from its system to “ICIS-WENDB” will be

considered in the alternative analysis if completed by May 30. During the summer, SRA will analyze the three alternatives and evaluate

them against the Evaluation Criteria (provided to the states on February 1, 2008).

During the summer, SRA may contact one or more states with specific questions on an alternative.

SRA will submit a final Alternative Analysis Report to EPA in September. EPA will share this report with the states.