UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20460 

OFFICE OF 

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 am pleased 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 a reliable 

and effective automated information system for the National Pollutant 

Discharge Elimination System (NPDES) program. 

PCS is the national data base for the NPDES program. It 

serves as the primary source of NPDES information for EPA, NPDES 

States, Congress, and the public. The use and support of PCS by 

EPA Regions and NPDES States are crucial to the effectiveness and 

proper oversight of the NPDES program. This policy statement 

establishes for EPA and NPDES States the key management practices 

and responsibilities central to PCS' ability to contribute to the 

overall integrity of the NPDES program and the achievement of our 

long-term environmental goals. One of the requirements is to have 

Regions and States enter all required data into PCS by September 30, 

1986 (see Attachment 1 of the PCS Policy Statement). While the aim 

of the policy is a consistent approach across Regional and State 

NPDES programs, it retains flexibility for Regions and States to 

tailor agreements to the unique conditions of each State. 

The PCS Policy 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 a strong commitment to this policy statement 

by EPA and State NPDES programs. You can be assured of my full 

support as EPA and the States move forward with its implementation. 

Attachments 

cc: Administrator 

Deputy Administrator 

State Directors 

PCS Steering Committee 

PCS Users Group 
PERMIT COMPLIANCE SYSTEM POLICY STATEMENT 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

STATEMENT OF POLICY 

It is EPA policy that the Permit Compliance System (PCS) shall 

be the national data base for the National Pollutant Discharge 

Elimination System (NPDES) program. All EPA Regions must use PCS 

directly, and all NPDES States must either use PCS directly or 

develop and maintain an interface. 

As our primary data source, PCS will promote national consistency and uniformity in permit and compliance evaluation. To 

achieve national consistency and uniformity in the NPDES program, 

the required data in PCS must be complete 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 1 and 2. 

They comprise the Water Enforcement National Data Base (WENDB) 

which has been redefined as the core of information necessary to 

enable PCS to function as a useful operational and management tool 

and so that PCS can be used to conduct oversight of the effectiveness of the NPDES program. 

All required data for NPDES and non-NPDES States must be 

entered into PCS by 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 FY 1986. 

By the end of FY 1986, direct users of PCS shall establish, 

with Office of Water Enforcement and Permits (OWEP) assistance, 

a Quality 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 PCS in a timely manner; and 

° nationally consistent standards of known data quality 

based on proven statistical methods of quality assurance. 

PCS Quality Assurance shall address the completeness (for 

assurance of full data entry) and accuracy of the data 

entered into PCS. 

Adoption of PCS by States should be formalized in each 

State's §106 Program Plan, State/EPA Agreement, or in a separate 

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 

When the PCS Steering Committee met in March 1985, EPA 

Regional representatives stressed the essential need for a positive 

statement from EPA Headquarters 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 EPA Headquarters, Regional, and State 

support, however, PCS will come to serve several major purposes 

for the NPDES program: 

° PCs will provide the overall inventory for the NPDES program. 

° PCS will provide data for responding to Congress and the 

public on the overall status of the NPDES program. As 

such, it will serve as a valuable tool for evaluating the 

effectiveness of the program and the need for any major 

policy changes. 

° PCS will encourage a proper EPA/State oversight role by identifying all major permittee violators. 

° PCS will offer all levels of government an operational and 

management tool for tracking permit issuance, compliance, 

and enforcement actions. 

This PCS Policy Statement is a result of the Steering Committee 

meeting. It is a clear message to Regional and State management 

that PCS is the primary source of NPDES information, and as 

such, it is to be supported wholeheartedly by all users of PCS, 

The PCS Steering Committee meeting also resulted in a 

redefinition of WENDB and ratification thereof. WENDB is the 

minimum standard of data entry which will allow PCS to function 

as a useful operational and management tool (see Attachments 1 

and 2). EPA Regions agreed that all WENDB elements will be 

entered into PCS by September 30, 1986, and maintained regularly 

thereafter. 

Once the required data are entered into and regularly maintained in PCS, PCS will assist permits and compliance personnel 

in many of their operational and management responsibilities. 

PCS will 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 PCS Policy 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 FY 1986: 

- All required National Municipal Policy (NMP) data must be 

entered into PCS by October 31, 1985 (See Attachment 1). 

- All required data for non-NPDES States must be entered 

into PCS by March 31, 1986. 

° NPDES permits shall be enforceable and tracked for compliance using PCS. The Office of Water Enforcement and 

Permits (OWEP) recognizes there may be situations where 

permit limits and monitoring conditions are not initially 

compatible with PCS data entry and tracking. In these 

cases, Regions should ensure that appropriate steps are 

taken by the permit writer to identify difficult permits 

to the PCS coder, 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 NPDES permits. 

° WENDB is the minimum standard of data entry for PCS (see 

the attached lists of data requirements). If States and 

Regions wish to enter NPDES data beyond what has been required, 

they may do so. For example, if States want to enter 

Discharge Monitoring Report (DMR) data for minor facilities, 

the option is available in PCS and the States' may use it 

as their resources allow. EPA will ensure that sufficient 

computer space is available for the currently projected 

use of PCS. 

° All DMRs submitted to EPA Regional Offices (including DMRs 

submitted by NPDES States for EPA entry into PCS) must be 

preprinted using the Office of Management and Budget (OMB) 

approved DMR form. NPDES States directly using PCS are 

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 

NPDES States' benefit to preprint DMRs. The use of preprinted DMRs will greatly reduce PCS' data entry burden, 

making available resources to be used in other areas 

(e.g., PCS quality assurance, data entry for other PCS 

records, etc.). 
-4- 

° The frequency with which DMRs are submitted to the EPA or 

NPDES State is important for ensuring timely entry of 

data into PCS and timely review of permittee's compliance 

status. Quarterly, semi-annual, or annual submission of 

DMRs creates a major data entry burden and impedes the 

compliance evaluation process. As a result, the usefulness of DMR data for compliance evaluation decreases 

substantially, Monthly submittal of DMRs alleviates this 

problem and enhances PCS' effectiveness significantly. It 

is recommended that monthly submittal of DMRs be incorporated into major permits as they are reissued. With approximately 20 percent of the permits reissued each year, it 

will take five years to complete the transition to monthly 

submittal for all major permittees. 

° EPA Regions should coordinate with their respective States 

to develop strategies that describe each State's plans to 

either use PCS directly or develop an interface. These 

strategies should include the rationale for selecting one 

of these 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 a schedule for attainment not to exceed 

September 30, 1986. If a State is a current user of PCS 

via one of these methods, the strategy should describe its 

needs for enhancing its PCS usage or improving its PCS 

interface, the mechanisms to be used to supply sufficient 

resources, and a schedule for attainment not to exceed 

September 30, 1986. 

° When writing or revising a Memorandum of Agreement (MOA), 

the Region and State should specify the State's intent to 

use or interface with PCS. The MOA should 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 a schedule 

for attainment. 

Responsibilities 

Office of Water Enforcement and Permits: It is OWEP's full 

responsibility to maintain the structure i.e., the computer 

software) of PCS and to operate the system. OWEP will continue 

to support time-sharing funds needs, training, and the necessary 

resources to continue the operation of PCS. OWEP will work with 

the EPA Regions and NPDES States to continually evaluate and 

improve, where feasible, the system's software, time-share funding, 

operation, and maintenance. OWEP will maintain a Steering Committee and User Group, organize the national meetings, and work 

closely with the Regional and State representatives on major 

decisions related to PCS. 

OWEP will oversee the Regions' and States' progress in 

fulfilling this policy statement by assessing the quantity of 

data entered each quarter. 
-5- 

EPA Regions and NPDES‘ States: It is the EPA Regions* and 

NPDES States' full responsibility to maintain the infrastructure 

of PCS by accurately entering data in a timely manner. Also, EPA 

Regions and NPDES States are responsible for participating in PCS 

Workgroups and contributing to improvements to PCS. 

Three National PCS meetings are held each year, one for the 

Steering Committee and two for the PCS Users Group. EPA Regions 

are expected to attend all three meetings. NPDES States directly 

using PCS are invited to attend the State portions of these 

meetings. More meetings may be scheduled during the year if 

necessary. 

Since consistent and objective compliance tracking is a 

central component of an effective and credible enforcement program, 

NPDES States are strongly urged to use PCS directly. We realize, 

however, that there may be some cases where NPDES States cannot 

use PCS directly. In these instances, in accordance with §123.41 

of the regulations, EPA requests from the States all required 

information (as indicated in the attachments) for entry into PCS. 

This can be achieved one of two ways: 

° A State Automated Data Processing (ADP) interface can be 

developed. It is the EPA Region's responsibility to work 

with the NPDES State to develop an effective State ADP 

interface. The State, however, should take the lead in 

developing the interface and work 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 a State ADP interface is developed, there 

must be formal agreement that the State will operate the 

interface, maintain the interface software, and be fully 

responsible for making any changes to the interface based 

on changes made to its automated data base. This will 

ensure that the NPDES State will be held responsible for 

system compatibility. If the State does not accept full 

responsibility with system compatibility, then changes 

must not be made to the State system without the prior 

knowledge of EPA. The State is responsible for ensuring 

that the data are transferred to PCS in a timely manner, 

accurately, and completely. Interfaces must be developed 

and maintained so that they operate with maximum efficiency 

all of the time. 

° OWEP recognizes that FY 1986 will be a transition year for 

PCS. NPDES States will begin using PCS or will develop 

interfaces. In the event that neither of these alternatives 

is accomplished by the end of FY 1986, in accordance with 

the FY 1986 Guidance for the Oversight of NPDES Programs, 

the State will be responsible for submitting all required 

information (as indicated in the attachments) in hard 

copy format. The data must be submitted either already 
-6- 

coded onto PCS coding sheets or in a format that can be 

readily transferred onto PCS coding 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 

EPA Region's responsibility to enter the data into PCS in a 

timely manner. 

Funding 

° §106 grant funds may be used for interface software development. However, they cannot be used for maintenance of the 

interface software for State-initiated changes to a State 

ADP system or for the operation and maintenance of a separate 

State ADP system. 

° §106 grant funds may be used for State data entry if and 

only if the State uses PCS directly or the State provides 

data to PCS via an interface that meets the standards of 

this policy. 

° If requested by a State, EPA will 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. 

Date Assistant Administrator for Water 
ATTACHMENT 1 

REQUIRED DATA TO BE ENTERED INTO PCS 

Information Type1 

Permit Facility Data 

Permit Event Data 

Inspection Data 

Parameter Limits and 

Pipe Schedule Data 

Compliance Schedule 

Data 

DMR Measurement 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 as described 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. 
ATTACHMENT 2 

WATER ENFORCEMENT NATIONAL DATA BASE (WENDB) ELEMENTS 

Data Element Name Acronym 

COMMON KEY 

NPDES Number NPID 

COMPLIANCE SCHEDULE RECORD 

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 

COMPLIANCE VIOLATION 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 

ENFORCEMENT ACTION 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; can be manually entered. 
WENDB ELEMENTS 

(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 STORET Parameter 

Action Discharge Designator 

Action Compliance Schedule 

Action Violation Type 

EVIDENTIARY HEARING RECORD 

Evidentiary Hearing Event Date 

Evidentiary Hearing Event Code 

INSPECTION RECORD 

Inspection Date 

Inspector Code 

Inspection Type 

MEASUREMENT VIOLATION RECORD 

Measurement Concentration Average 

Measurement Concentration Minimum 

Measurement Concentration Maximum 

Measurement Quantity Average 

Measurement Quantity Maximum 

Violation Date (Measurement) 

No Discharge Indicator 

*Significant Non-Compliance Code 

(Measurement) 

*Significant Non-Compliance Date 

(Measurement) 

Violation Measurement Designator 

Measurement Discharge Number 

Violation Monitoring Location 

Violation STORET Parameter 

PARAMETER LIMITS RECORD 

Change of Limit Status 

Contested Parameter Indicator 

Modification Period End Date 

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 

LQAV 
WENDB ELEMENTS 

(Continued) 

Data Element Name 

Quantity Maximum Limit 

Quantity Unit Code 

Limit Type - Alphabetic 

Monitoring Location 

Modification Number 

Limit Discharge Number 

Limit Report Designator 

STORET Parameter Code 

Season Number 

Statistical Base Code 

PERMIT EVENT RECORD 

Permit Tracking Actual Date 

Permit Tracking Event Code 

PERMIT FACILITY RECORD 

River Basin 

City Code 

County Code 

Type Permit Issued - EPA/State 

Federal Grant Indicator 

Final Limits Indicator 

Average Design Flow 

Facility Name Long 

Facility Inactive Code 

Major Discharge Indicator (Entered 

by EPA Headquarters) 

Pretreatment Program Required 

Indicator 

SIC Code 

Type Ownership 

National Municipal Policy 

Tracking Indicator 

Significant Noncompliance Flag for 

P.L. 92-500 Minor Facilities 

PIPE SCHEDULE RECORD 

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 Be Created) 

DRID 

DSCH 

FLED 

FLSD 

MLED 

MLSD 

ILED 

ILSD 

NRPU 

NSUN 

NSUS 
WENDB ELEMENTS 

(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: 

New total: 

IADD 

RCIN 

PIDT 

111 WENDB elements 

+ 9 data elements 

120 WENDB elements