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### MEMORA **NDUM** TO: Public Record for the NPDES Electronic Reporting Rule

EPA Docket Number EPA
- HQ
- OECA
- 2009
- 0274 (www.regulations.gov) FROM: Carey

A. Johnston, P.E. USEPA/OECA/OC ph: (202) 566 1014 johnston.carey @epa.gov DATE: 1 7 November 2011 SUBJECT: Description of the PCS and ICIS
-NPDES [DCN 0008] 

### A. **The Permit Compliance System (PCS)** EPA uses the Permit Compliance Sy stem (PCS), a national data s ys tem developed in 1982, to support the NPDES program. PCS, which is managed b y the Office of Enforcement and Compliance Assurance (OECA), is a critical information sy stem for EPA’s Office of Water and OECA. PCS tracks NPDES permit issuance, permit limits, self
- monitoring data, enforcement and inspect ion activity

for NPDES facilities regulated under the CWA. PCS currentl y tracks data for 16 states. The data from 34 other states, 19 territories, 2 tribes and 10 EPA Regional offices that had previousl y been in PCS were migrated to ICIS
- NPDES, the moderni zed sy stem 1 . PCS, identified as a mission critical sy stem for the Agency , is one of the Agency’s largest and most complex systems, given the large number of transactions and the variet y of information sources for hundreds of thousands of NPDES permittees. The NPDES Discharge Monitoring Reports (DMRs) that the permitting authorities collect and process constitute the second largest data collection effort within the federal government, accounting for close to 30 million records. The PCS Policy

Statement (as amended) identified the data elements that were expected to be entered or otherwise provided b y the states to EPA through PCS. This policy statement and accompan yi ng data requirements allowed PCS to function for many years as a useful management tool for the NPDES program, providing EPA with a nationally consistent set of facility
- specific NPDES information, particularly for major facilities. 

### B. **The NPDES component of the Integrated Compliance Information System (ICIS****** **NPDES)** The Integrated Compliance Infor mation Sy stem (ICI S) serves as the repository for multi
media compliance and enforcement data at the federal level. The development of I CI S was divided into three phases. The first phase focused on developing a s ys tem to integrate federal enforcement and c ompliance activities. The second phase focused on the incorporation of the NPDES program specific requirements, thus creating the IC IS
- NPDES component which is

1 See EPA’s website ( http://www.epa
- echo.gov/echo/compliance_report_water.html ) for a current listing of states, tribes, and territories that report to PCS or ICIS
-NPDES.2

intended as a replacement national NPDES data system for PCS. The third phase, under discussion, may

add air
- related program
- specific requirements. 

### C. **Why the Change from PCS to ICIS -**  **NPDES?** When EPA and the NPDES
- authorized states developed the Water Enforcement National Data Base (WENDB) list of data elements for PCS, NPDES agencies were focused on the control and reduction of pollutant discharges from the identified point sources of pollution that were priorities for national attention at the time, specificall y, major dischargers. The NPDES program has evolved considerabl y since then. EPA now recogn izes the need to better quantify and address the environmental impacts from nonmajor point sources (including wet weather sources) as well. The changes in the focus of the NPDES program implementation necessitate change in the data to be tracked and in the areas in which program oversight is conducted. Given the significant advances in computer technology in the past twent y years, the underlying database technology supporting the PCS data sy stem has grown increasingl y outdated and unsupported, making it impractical to upgrade and difficult for EPA and NPDES
- authorized states to maintain. The PCS data sy stem is also not capable of handling the increase in the expanded NPDES universe. EPA and states modified their NPDES data s ys tems to address new program requirements, but not necessaril y in a nationally consistent or methodical manner. Without a systematic approach, difficulty obtaining the necessary

data to make strategic program decisions from each state and EPA Region, including data needed to respond to r equests received by EPA, hampers EPA’s ability to provide timely

responses to both Congress and the public on pollutant discharges and trends of national or regional significance. This lack of timely access to nationally consistent NPDES information from the states has undermined the Agency ’s capacit y to conduct program oversight and to make the best
- informed program management decisions. EPA has worked closely

with its state partners in an effort to modernize PCS and eventuall y replace it with I CI S
- NPDES. IC IS
- NPDES was designed to improve EPA’s and states’ ability

to track and manage information related to all NPDES sources. The new ICIS
NPDES ensures that the more traditional NPDES information remains available, accessible, and useful, and also provides means to track and access other NPDES information that was not historically

available in PCS. There are substantial benefits derived from a more modern NPDES data s ys tem. Through this rule’s requirement for electronic reporting of NPDES information, I CIS
- NPDES will capture information for all permitted NPDES sources, improve NPDES agencies’ capacity to evaluate compliance, perform watershed anal ys is, evaluate trends in NPDES program implementation, and report to Congress. ICI S
- NPDES would continue to suppo rt the public’s access to information through Agency web sites providing a more complete picture of the NPDES program for EPA, its state partners, Congress and the public.