Proposed Charge for Matrix Priority Work Group

Proposed Charge for Matrix Priority Work Group July 10, 2006 draft for Work Group Review

History of Document: First drafted created by EPA on June 22. Edits made by Mary Blakeslee to incorporate state comments from June 28th conference call. Additional revisions made based on discussions between Work Group co-chairs, David Hindin and Bob Zimmerman, July 6 and 10. Both co-chairs are comfortable with document going out for Work Group discussion on July 12th conference call.

Purpose Per general consensus decision at the June 9, 2006, meeting of the State EPA Expanded ICIS/PCS Steering Committee, we agreed to form a Matrix Priority Work Group to develop a proposed approach for transitioning the NPDES management information provided to USEPA from where states are today (almost WENDB) to RIDE.1 The concurrent system transition from PCS to ICIS is a component which may require some special attention. This involves categorizing the universes (e.g., majors, minors with DMRs, minors without DMRs, program areas) and identifying, milestones and/or priorities (e.g., technology solutions) for when data is available (e.g., new CAFO regulations, wet weather SNC implementation).

Key Milestones 1. At its first conference call (last week of June) and in the July 12, 2006 conference call, the Work Group will review this Proposed Charge, modify it as appropriate and then move forward. 2. Create a draft Matrix that delineates the key programs, milestones, and data elements and includes options for how and when if more than one approach is proposed (using the work started at the June meeting). 3. Discuss and reach consensus on the information in the draft Matrix and or identify issues for the full Steering Committee review and discussion. 4. The Work Group has a milestone of developing a draft proposal by July 31, 20062, which proposal will then be reviewed by the full Expanded Steering Committee shortly thereafter. Given time constraints, the draft proposal may be limited to a detailed listing of the issues with proposed options for resolving each issue. The Matrix should provide a graphical representation of the issues and options. 5. After review by the Expanded Steering Committee in conjunction with the report from the other work group examining a potential Model for Resource Estimating, the draft proposal is expected to be presented at the ASIWPCA Annual Meeting in New Orleans on August 13/15 and the ECOS Annual Meeting in Portland, OR

1 States have not agreed with RIDE as it is currently proposed in the ICIS-NPDES Draft Policy Statement. 2 States and EPA believe that this date is a target so there can be further dialog on progress to date prior to the ECOS meeting

1 on August 27/29. The proposal will be presented by a state and EPA representative.

Key Issues the Work Group Should Address 1. What is an appropriate transition period for moving from WENDB3 to RIDE? And how does this transition for required data elements, relate to the system transition from PCS to ICIS-NPDES? Are these two transitions essentially the same, or do they differ in certain ways? 2. What criteria should be used to determine the transition period for moving from WENDB to RIDE for each State? Are there milestones/pre-conditions that must be addressed, e.g. system stability, upload tools, etc? When should the transition begin? For direct user states, when the Policy Statement is issued? For batch states, when the XML schemas are final? After a direct user state has had X months of using ICIS-NPDES? 3. Assuming states will have different challenges in moving from WENDB to RIDE, do we need to provide states with flexibility during the transition period? How much variability is there in these challenges, and would categorizing states help us better understand and address these challenges? For example, states that have all of RIDE in an existing state electronic information management system may differ from states that manage some of the RIDE information in a paper manner. 4. How should we proceed to reduce the existing state variability during the transition period while not exacerbating the problem? EPA has a need for usable, consistent, predictable data from across the states to provide national reports. The longer the transition period, the more critical this EPA need becomes. Would a phased approach with milestones provide sufficient predictability and certainty that national variability would be reduced during the transition period? 5. Universe Prioritization. Is there some priority subset of facilities that can be easily and consistently identified across the country that would be valuable to prioritize for coming into RIDE sooner? For the special program areas, can these be prioritized in a nationally consistent way for moving to RIDE? 6. Data Family Prioritization. Are there prioritization options for data families? For example, do we prioritize requiring single event violation data for non-majors of a certain size or characteristic or sector? How does the wet weather SNC Policy (when finalized) factor into this prioritization?

7. General Permit Covered Facilities. Do we need to clarify how ICIS and RIDE applly to General permit covered facilities? Is there a need to prioritize general

3 Everyone acknowledges there is some variability among states reporting of WENDB data elements today. While the vast majority of states are achieving the easy to measure goal of 95% completeness for major limits and DMRs, there are some data families in which many states are not providing certain data elements (such as Single Event Violations). There are some states that are going beyond WENDB, for example, by entering the limits and DMRs for many of their non-majors.

2 permit covered facilities for coming into ICIS and RIDE in addition to the other prioritization schemes? 8. Underlying Regulatory Triggers. Are there changes in particular NDPES program areas (e.g. CAFO) that need to occur before authorized states or regions will have certain RIDE data? 9. Electronic DMRs. Should entry of DMR data for non-majors that is currently not being entered be delayed until the authorized state or region has an operational electronic DMR tool for their facilities to use?

Members of Priority Work Group The EPA co-chair will be David Hindin, with Betsy Smidinger as his alternative. EPA members are: Kate Anderson - OECA/OCE/WED; Tom Laverty - OW; Martha Segall – OW; and Joan Karnauskas – Region 5.

The State co-chair will be: Bob Zimmerman - Delaware. The state members are: Bob Scott – Georgia; Mike Garretson – Illinois; Melanie Morris – Mississippi; Joe Dimura – New York; and Janice Brogle – New Jersey and Annette Liebe -- Oregon.

Work Group Procedures The Work Group will hold weekly conference calls. In recognition of the tight timeline, conference calls will be held as long as there are at least two EPA and two State members available. Conference calls will be scheduled by the co-chairs and documents exchanged electronically directly among work group members.

Key Background Documents 1. December 2005 draft ICIS-NPDES Policy Statement. 2. Previous Efforts in RIDE Prioritization and Categorization from March 2005 Steering Committee meeting. 3. Two diagrams showing WENDB to RIDE for Majors and Non-Majors 4. Independent Review of the ICIS –NPDES Batch Release by ERG, June 7, 2006. (A final version of this document should be available by early August.) 5. EPA White Paper: Management and Data Needs for the CWA NPDES Program, March 21, 2006. 6. States’ White Paper: Alternative Approaches for States to Provide USEPA with NPDES Information – May 2006. 7. ASIWPCA Observations & Recommendations: ICIS-NPDES Data System & Policy Statement, June 2006.