Integrated Compliance Information System (ICIS) and the Exchange by ngs20854

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									Integrated Compliance Information System (ICIS) and
              the Exchange Network



        Exchange Network National Meeting
        Nashville, TN, April 30, 2008




           David A. Hindin, Director
           Enforcement Targeting and Data Division
           Office of Compliance
           Office of Enforcement and Compliance Assurance
Purpose

   Review ICIS-NPDES (PCS
    Modernization) phased approach, with
    emphasis on Exchange Network Flows.
   Status of Alternative Analysis for ICIS-
    NPDES full batch.




                                               2
                               ICIS Phased Approach

Federal Enforcement         National Pollutant Discharge Elimination System                  Clean Air Act
  and Compliance                                 NPDES                                    Stationary Sources

Implemented FY 2002     Direct Users Batch Release       Batch Release   Batch Release    Modernization of
                                       Part 1            Part 2          Part 3           the CAA Air
                                       Hybrid Users      NetDMR          Full Batch
Replaced 3 outdated     Implemented                                                       Facility System –
national systems and      FY 2006                                                         (AFS)
                                       May 5, 2008       Aug 2008:      Begin work
several regional                       Implement 1       “demonstrable” FY 2009
tracking systems.                      State                                              AFS tracks permit
                                                         done per
Integrates with FRS.    • 21 States                                                       compliance and
                                                         Grant.         For 22
                        • 2 Tribes      August 2008                                       enforcement data
                        • 9 Territories Implement 4 to 6                States to         for major stationary
Used by HQ and                          States.          FY09:           electronically
Regions to manage                                                                         sources.
                                                         Testing and    transfer all
enforcement and         More recent     FY09: Implement Implement
                        program                                         their data        FY2008: Developing
compliance. Supports                    2 to 4 states
                                                                         from their       Business requirements
annual results public   requirements
                                                         Permittees     state system.
reporting, such as      • CAFO          Direct entry of
                                                         electronically
GPRA pounds of          • Storm water all data except
                                        DMR data,        sign & submit May be revised
pollutants reduced.     • CSO                                           based on
                                        which will be     DMRs.
                        • SSO           electronically                   Alternative
                                       transferred.                      Analysis

                                                      Exchange Network
      Phase I                                                                                 Phase III
Enforcement Docket                     Phase II: PCS Modernization                        AFS Modernization

                                                                                                         3
          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.

                                                                          4
                     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.




                                                                                     5
         Architecture for flowing DMR data from state systems
         via the Exchange Network to ICIS-NPDES
                                                    State User

                                                    NPDES Data

                                                    State Node
                                                                                             Firewall

                         1. Authenticate                                      11. Download

                                    2. Submit                      10. getStatus
                                                            9. Authenticate




                 3.                         CDX/Exchange Network
Pre-Process   Process
                                                   Node services
                            (including NAAS, node archive, virus check, schema validation)


                                     4.          6.          7.       8.
                                   Submit   Authenticate   Submit    Notify                  Firewall


                        ICIS
                        Batch Node




                                         5.
                                    Process Batch

                         ICIS
                         Batch Processing



                                                                                                        6
                                          ICIS Hybrid Batch Submission Process

              State NPDES                                                          ICIS Batch
                                             CDX                                   logs errors
                 System                     sends
                                           XMLs to
                                             ICIS



                  State                                                             ICIS
             generates and                    XML         Yes         No            done
               zips XMLs                       file                                parsing
                                             errors                                   ?
                                                ?                                      Yes

                                                  No
                                                                                 ICIS Batch sets status
                                State                                             to “Completed” and
State                        electronic   ICIS Batch                               sends PDF to CDX
Uploads to                       ally       parses
CDX                           submits       XMLs
manually                     to CDX via
                                Node



                                                                State node               State
                                              XML
                                                                gets status               user
                                              data
                                                          Yes       and                  views
                  XML                        errors
                                    Yes                         downloads                status
                  files                        ?
                                                                errors from                and
                  virus                           No                CDX                  errors
                free and                                                                on CDX
                 valid?                                                                   web
                                                                                          form
                     No
                                           ICIS Batch
                                          saves data in
                                          ICIS-NPDES
        CDX logs first 100                                          State views batch accepted,
      errors and sets status                                       rejected, summary reports in
            to “Failed”                                                         ICIS




                                                                                                          7
                    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
                                                                                           8
            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.




                                                                                              9
            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.




                                                                                              10
                                        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




                                                                                           11
                          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.




                                                                                           12
                     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.)

                                                                                        13
    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.


                                                                                14
         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.



                                                                               15
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.




                                            16
Summary of Alternatives

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




                                                                 17
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.



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