UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY WASHINGTON.

D.C.20460

OFFICEOF WATER MEMORANDUM SUBJECT: Permit Compliance System (PCS) Policy Statement FROM: Lawrence J. Jensen

Assistant Administrator for Water (WH-556) TO: Regional Water Management Division Directors

Regions I - X I ampleased to issue the attached policy statement on the Permit Compliance System (PCS). This policy statement represents an important step in the continuing effort to support areliable and effective automated information system for the National Pollutant Discharge Elimination System (NPDES) program. PCSis the national data base for the NPDESprogram. It serves as the primary source of NPDESinformation for EPA, NPDES States, Congress, and the public. The use and support of PCSby EPARegions and NPDESStates are crucial to the effectiveness and proper oversight of the NPDESprogram. This policy statement establishes for EPAand NPDESStates the key management practices and responsibilities central to PCS' ability to contribute to the overall integrity of the NPDESprogram and the achievement of our long-term environmental goals. Oneof the requirements is to have Regions and States enter all required data into PCSby September 30, 1986 (see Attachment 1of the PCSPolicy Statement). While the aim of the policy is aconsistent approach across Regional and State NPDESprograms, it retains flexibility for Regions and States to tailor agreements to the unique conditions of each State. The PCSPolicy Statement is effective immediately. The Office of Water Enforcement and Permits will monitor implementation of the policy statement and issue special instructions as necessary. Regional Water Management Division Directors and their State counterparts are responsible for ensuring that their staffs receive sufficient support to apply the principles of the policy to their PCS activities.
I look forward to astrong commitment to this policy statement by EPAand State NPDESprograms. Youcan be assured of myfull support as EPAand the States move forward with its implementation. Attachments

cc: Administrator Deputy Administrator State Directors PCSSteering Committee PCSUsers GroupPERMITCOMPLIANCESYSTEMPOLICY STATEMENT UNITED STATESENVIRONMENTALPROTECTIONAGENCY STATEMENTOFPOLICY It is EPApolicy that the Permit Compliance System (PCS) shall be the national data base for the National Pollutant Discharge Elimination System (NPDES) program. All EPARegions must use PCS directly, and all NPDESStates must either use PCSdirectly or develop and maintain an interface.
As our primary data source, PCSwill promote national consistency and uniformity in permit and compliance evaluation. To achieve national consistency and uniformity in the NPDESprogram, the required data in PCSmust becomplete and accurate. Facility, permits (i.e., events and limits), measurement, inspection, compliance schedule, and enforcement action data are required. These required data elements are further defined in Attachments 1and 2. They comprise the Water Enforcement National Data Base (WENDB) which has been redefined as the core of information necessary to enable PCSto function as auseful operational and management tool and so that PCScan be used to conduct oversight of the effectiveness of the NPDESprogram. All required data for NPDESand non-NPDES States must be entered into PCSby September 30, 1986 and maintained regularly thereafter. This will require Regions and States to start entering data as early as possible, and not wait until late FY1986. By the end of FY1986, direct users of PCSshall establish, with Office of Water Enforcement and Permits (OWEP)assistance, aQuality Assurance program for data in PCS. The program shall define:
°monthly measurement of the level of data entered:
° appropriate time frames to ensure that data are entered in PCSin atimely manner; and
° nationally consistent standards of known data quality based on proven statistical methods of quality assurance. PCSQuality Assurance shall address the completeness (for assurance of full data entry) and accuracy of the data entered into PCS. Adoption of PCSby States should be formalized in each State's §106 Program Plan, State/EPA Agreement, or in aseparate agreement. Each plan should clearly define EPA's and the NPDES State's responsibilities regarding PCS. The Key Management Practices in this Policy Statement should be incorporated into the §106 Program Plan.-2-

BACKGROUND
Whenthe PCSSteering Committee met in March 1985, EPA Regional representatives stressed the essential need for apositive statement from EPAHeadquarters management to Regional and State management specifically requiring the support and use of PCS. Lack of such support may result in an incomplete and unreliable data base. With sufficient EPAHeadquarters, Regional, and State support, however, PCSwill cometo serve several major purposes for the NPDESprogram: °PCs will provide the overall inventory for the NPDESprogram. ° PCSwill provide data for responding to Congress and the public on the overall status of the NPDESprogram. As such, it will serve as avaluable tool for evaluating the effectiveness of the program and the need for any major policy changes.
° PCSwill encourage aproper EPA/State oversight role by identifying all major permittee violators.
° PCSwill offer all levels of government anoperational and management tool for tracking permit issuance, compliance, and enforcement actions.
This PCSPolicy Statement is aresult of the Steering Committee meeting. It is aclear message to Regional and State management that PCSis the primary source of NPDESinformation, and as such, it is to be supported wholeheartedly by all users of PCS,
The PCSSteering Committee meeting also resulted in a redefinition of WENDBand ratification thereof. WENDBis the minimum standard of data entry which will allow PCSto function as auseful operational and management tool (see Attachments 1 and 2). EPARegions agreed that all WENDBelements will be entered into PCSby September 30, 1986, and maintained regularly thereafter. Once the required data are entered into and regularly maintained in PCS, PCSwill assist permits and compliance personnel in many of their operational andmanagement responsibilities. PCSwill greatly reduce reporting burdens for such activities as the Strategic Planning and Management System (SPMS), and it will reduce efforts needed for effective compliance tracking at both Regional and State levels. Also, substantial automation of the Quarterly Noncompliance Report (QNCR)will save time and resources.-3-

IMPLEMENTATION STRATEGY Key Management Practices To effectively implement and uphold this PCSPolicy Statement and enhance PCS' capabilities, there are certain key management practices that must be implemented: ° The following milestones have been established to facilitate the entry of all required data by the end of FY1986:

- All required National Municipal Policy (NMP) data must be entered into PCSby October 31, 1985 (See Attachment 1).

- All required data for non-NPDES States must be entered into PCSby March 31, 1986.
° NPDESpermits shall beenforceable and tracked for compliance using PCS. The Office of Water Enforcement and Permits (OWEP)recognizes there maybe situations where permit limits and monitoring conditions are not initially compatible with PCSdata entry and tracking. In these cases, Regions should ensure that appropriate steps are taken by the permit writer to identify difficult permits to the PCScoder, and to mutually resolve any coding issues. The Regions should work closely with their NPDES States using PCS, to address similar data entry problems with State-issued NPDESpermits.
°WENDBis the minimum standard of data entry for PCS(see the attached lists of data requirements). If States and Regions wish to enter NPDESdata beyond what has been required, they maydo so. For example, if States want to enter Discharge Monitoring Report (DMR)data for minor facilities, the option is available in PCSand the States' may use it as their resources allow. EPAwill ensure that sufficient computer space is available for the currently projected use of PCS.
°All DMRssubmitted to EPARegional Offices (including DMRs submitted by NPDESStates for EPAentry into PCS)must be preprinted using the Office of Management and Budget (OMB) approved DMRform. NPDESStates directly using PCSare not required to use the OMB-approved form: however, its use is strongly encouraged. With the continuing demand for more complete information and with stable, if not diminishing, data entry resources, it is to EPA's and NPDESStates' benefit to preprint DMRs. The use of preprinted DMRswill greatly reduce PCS' data entry burden, making available resources to be used in other areas (e.g., PCSquality assurance, data entry for other PCS records, etc.).-4-

°The frequency with which DMRsare submitted to the EPAor NPDESState is important for ensuring timely entry of data into PCSand timely review of permittee's compliance status. Quarterly, semi-annual, or annual submission of DMRscreates amajor data entry burden and impedes the compliance evaluation process. Asaresult, the usefulness of DMRdata for compliance evaluation decreases substantially, Monthly submittal of DMRsalleviates this problem and enhances PCS' effectiveness significantly. It is recommended that monthly submittal of DMRsbe incorporated into major permits as they are reissued. With approximately 20percent of the permits reissued each year, it will take five years to complete the transition to monthly submittal for all major permittees.
° EPARegions should coordinate with their respective States to develop strategies that describe each State's plans to either use PCSdirectly or develop an interface. These strategies should include the rationale for selecting one of these methods of data entry into PCS, anoutline of all requirements necessary for implementing the selected method, the mechanisms to be used to supply sufficient resources, and aschedule for attainment not to exceed September 30, 1986. If aState is acurrent user of PCS via one of these methods, the strategy should describe its needs for enhancing its PCSusage or improving its PCS interface, the mechanisms to be used to supply sufficient resources, and aschedule for attainment not to exceed September 30, 1986.
°Whenwriting or revising aMemorandum of Agreement (MOA), the Region and State should specify the State's intent to use or interface with PCS. The MOAshould address the rationale for-selecting one of these selected methods of data entry into PCS, an outline of all requirements necessary for implementing the selected method, the mechanisms to be used to supply sufficient resources, and aschedule for attainment. Responsibilities Office of Water Enforcement and Permits: It is OWEP'sfull responsibility to maintain the structurei.e., the computer software) of PCSand to operate the system. OWEPwill continue to support time-sharing funds needs, training, and the necessary resources to continue the operation of PCS. OWEPwill work with the EPARegions and NPDESStates to continually evaluate and improve, where feasible, the system's software, time-share funding, operation, and maintenance. OWEPwill maintain aSteering Committee and User Group, organize the national meetings, and work closely with the Regional and State representatives on major decisions related to PCS. OWEPwill oversee the Regions' and States' progress in fulfilling this policy statement by assessing the quantity of data entered each quarter.-5-

EPARegions and NPDES‘States: It is the EPARegions* and NPDESStates' full responsibility to maintain the infrastructure of PCSby accurately entering data in atimely manner. Also, EPA Regions and NPDESStates are responsible for participating in PCS Workgroups and contributing to improvements to PCS.
Three National PCSmeetings are held each year, one for the Steering Committee and two for the PCSUsers Group. EPARegions are expected to attend all three meetings. NPDESStates directly using PCSare invited to attend the State portions of these meetings. More meetings maybescheduled during the year if necessary. Since consistent and objective compliance tracking is a central component of an effective and credible enforcement program, NPDESStates are strongly urged to use PCSdirectly. Werealize, however, that there may be somecases where NPDESStates cannot use PCSdirectly. In these instances, in accordance with §123.41 of the regulations, EPArequests from the States all required information (as indicated in the attachments) for entry into PCS. This can be achieved one of two ways: °AState Automated Data Processing (ADP) interface can be developed. It is the EPARegion's responsibility to work with the NPDESState to develop aneffective State ADP interface. The State, however, should take the lead in developing the interface andwork closely with the Region to ensure the interface is effective. It should be realized that system interfaces are often troublesome and unwieldy: they are often ineffective and limit the States' flexibility to change their systems quickly to meet management needs. In the event aState ADPinterface is developed, there must be formal agreement that the State will operate the interface, maintain the interface software, and befully responsible for making any changes to the interface based on changes made to its automated data base. This will ensure that the NPDESState will beheld responsible for system compatibility. If the State does not accept full responsibility with system compatibility, then changes must not bemade to the State system without the prior knowledge of EPA. The State is responsible for ensuring that the data aretransferred to PCSin atimely manner, accurately, and completely. Interfaces must bedeveloped and maintained so that they operate with maximum efficiency all of the time.
°OWEPrecognizes that FY1986 will beatransition year for PCS. NPDESStates will begin using PCSor will develop interfaces. In the event that neither of these alternatives is accomplished by the end of FY1986, in accordance with the FY1986 Guidance for the Oversight of NPDESPrograms, the State will be responsible for submitting all required information (as indicated in the attachments) in hard copy format. The data must besubmitted either already-6-

coded onto PCScoding sheets or in a format that can be readily transferred onto PCScoding sheets. Also, the data must be submitted at regular intervals to ensure timely entry into PCS. Once the data are received by EPA, it is the EPARegion's responsibility to enter the data into PCSin a timely manner. Funding
° §106 grant funds maybe used for interface software development. However, they cannot be used for maintenance of the interface software for State-initiated changes to aState ADPsystem or for the operation and maintenance of aseparate State ADPsystem.
° §106 grant funds maybe used for State data entry if and only if the State uses PCSdirectly or the State provides data to PCSvia an interface that meets the standards of this policy.
° If requested by aState, EPAwill agree to pay for its time-sharing costs to implement this policy, within given resources. °Headquarters will continue to pursue alternative methods of reducing the data entry burden on Regions and States.

Assistant Administrator for Water DateATTACHMENT1

REQUIREDDATATOBEENTEREDINTOPCS

Information Type1 Permit Facility Data Permit Event Data Inspection Data Parameter Limits and Pipe Schedule Data Compliance Schedule Data
DMRMeasurement Data Significant Noncompliance Flag Enforcement Action Data (Enforcement Action Data, Compliance Schedule Data, and Interim Limits Data from all active formal enforcement actions) Enforcement Action Data (Type Action, ENAC; Issue Date, ENDT; and Date Compliance Required, ERDT; from all active formal enforcement actions) Pretreatment Approval2
National Municipal Policy Data3 X X

X
X

X Majors Minor 92-500s Other Minors X X X X X X X X X X

X

X X X X X X

1For each of the categories listed in this chart, the Information Type is the set of core data elements listed in Attachment 2. 2Pretreatment Program Required Indicator, PRET: one data element. 3All required data asdescribed in May 16, 1985 memorandum on National Municipal Policy Tracking in PCS. This includes Facility User Data Element 6 (RDF6), Compliance Schedule and Enforcement Action information.ATTACHMENT2

WATERENFORCEMENTNATIONAL DATABASE(WENDB)ELEMENTS

Data Element Name Acronym COMMON KEY NPDESNumber NPID COMPLIANCESCHEDULERECORD Compliance Schedule Number Data Source Code Compliance Actual Date Compliance Report Received Date Compliance Schedule Date Compliance Schedule Event Code CSCH DSCD DTAC DTRC DTSC EVNT COMPLIANCEVIOLATION RECORD *Compliance Violation Date *Violation Compliance Event Code *Compliance Violation Code *Significant Non-Compliance Code (Compliance) *Significant Non-Compliance Date (Compliance) *Violation Compliance Schedule Number *Violation Data Source Code CVDT CVEV CVIO SNCC SNDC VCSN VDCD ENFORCEMENTACTION RECORD Enforcement Action Response Achieved Date Enforcement Action Comment Line 1 Enforcement Action Comment Line 2 Enforcement Action Comment Line 3 Enforcement Action Comment Line 4 Enforcement Action Comment Line 5 Enforcement Action Compliance Violation Code Enforcement Action Compliance Violation Date Enforcement Action Modification Number Enforcement Action Code Enforcement Action Date Enforcement Action Status Code Enforcement Action Response Due Date Enforcement Action Status Date Enforcement Action Season Number Enforcement Action Source Code Enforcement Action Discharge Number EADR ECM1 ECM2 ECM3 ECM4 ECM5 ECVC ECVD EMOD ENAC ENDT ENST ERDT ESDT ESEA EVCD EVDS

* Usually generated by PCS; canbe manually entered.WENDBELEMENTS (Continued) Data Element Name Enforcement Enforcement Alphabetic Enforcement Enforcement Enforcement Code Enforcement Enforcement Enforcement Action Event Code

Action Limit TypeAction Monitoring Date Action Monitoring Location Action STORETParameter Action Discharge Designator Action Compliance Schedule Action Violation Type
EVIDENTIARY HEARINGRECORD Evidentiary Hearing Event Date Evidentiary Hearing Event Code INSPECTION RECORD Inspection Date Inspector Code Inspection Type MEASUREMENTVIOLATION RECORD
Measurement Concentration Average Measurement Concentration Minimum Measurement Concentration Maximum Measurement Quantity Average Measurement Quantity Maximum Violation Date (Measurement) NoDischarge Indicator *Significant Non-Compliance Code (Measurement) *Significant Non-Compliance Date (Measurement) Violation Measurement Designator Measurement Discharge Number Violation Monitoring Location Violation STORETParameter
PARAMETERLIMITS RECORD Change of Limit Status Contested Parameter Indicator Modification Period EndDate Modification Period Start Date Concentration Average Limit Concentration Minimum Limit Concentration Maximum Limit Concentration Unit Code Quantity Average Limit Acronym EVEV EVLM
EVMD EVML EVPR
EVRD EVSN EVTP

EHDT EHEV

DTIN INSP TYPI

MCAV MCMN MCMX MQAV MQMX MVDT NODI SNCE SNDE
VDRD VDSC VMLO VPRM

COLS CONP ELED ELSD LCAV LCMN LCMX LCUC LQAVWENDBELEMENTS (Continued)
Data Element Name Quantity Maximum Limit Quantity Unit Code Limit Type - Alphabetic Monitoring Location Modification Number Limit Discharge Number Limit Report Designator STORETParameter Code Season Number Statistical Base Code
PERMIT EVENTRECORD
Permit Tracking Actual Date Permit Tracking Event Code
PERMITFACILITY RECORD
River Basin City Code County Code Type Permit Issued - EPA/State Federal Grant Indicator Final Limits Indicator Average Design Flow Facility NameLong Facility Inactive Code Major Discharge Indicator (Entered by EPAHeadquarters) Pretreatment Program Required Indicator SIC Code Type Ownership National Municipal Policy Tracking Indicator Significant Noncompliance Flag for P.L. 92-500 Minor Facilities
PIPE SCHEDULERECORD Report Designator Discharge Number Final Limits End Date Final Limits Start Date Interim Limits End Date Interim Limits Start Date Initial Limits End Date Initial Limits Start Date Number of Units in Report Period Number of Units in Submission Period - EPA Number of Units in Submission Period - State Acronym LQMX LQUC LTYP MLOC MODN PLDS PLRD PRAM SEAN STAT

PTAC PTEV

BAS6 CITY CNTY EPST FDGR FLIM FLOW FNML IACC MADI
PRET SIC2 TYPO RDF6 (To BeCreated)

DRID DSCH FLED FLSD MLED MLSD ILED ILSD NRPU NSUN NSUSWENDBELEMENTS (Continued)
Data Element Name Pipe Inactive Code Report Units Initial Report Date Initial Submission Date - State Initial Submission Date - EPA Submission Unit - EPA Submission Unit - State Acronym PIAC REUN STRP STSS STSU SUUN SUUS

NOTE: Additional data elements subject to approval: Frequency of Analysis FRAN Sample Type SAMP Compliance Schedule File Number CSFN Enforcement Action File Number ERFN LSFN ICOM Permit Limits File Number Inspection Comments (First Three Characters for the Number of Industrial Users Inspected) Facility Inactive Date Reissuance Control Indicator Pipe Inactive Date

Total: plus additional data elements: Newtotal: IADD RCIN PIDT

111 WENDBelements + 9 data elements 120 WENDBelements