Resource Workgroup

Report to Expanded Steering Committee

Betsy Smidinger, EPA and David Pruitt, Oklahoma

August 10, 2006

1.  Resource Workgroup

·  Charge:

o  Develop a proposed consistent, reproducible model for estimating the resources of collecting and entering the Required ICIS-NPDES Data Elements (RIDE.)

§  The model should be applicable for determining national, as well as, state-by-state impacts.

§  This will involve determining estimates for relevant data collection resources and agreeing on assumptions to use in estimating the data entry resources.

·  Members: EPA: OECA/OW/Region 6,

States: NY, NJ, OK, AR, IA, GA, ASIWPCA, ECOS

2. Accomplishments

Model for Estimating Data Entry Resources

·  The Workgroup agrees with the model to estimate the data entry resources for RIDE. The model relies on many assumptions that can affect the model results. The Workgroup did not review each and every assumption; however, many of the significant assumptions were discussed.

·  The initial estimate from a data entry model is that on average a State will need between 2 ~ 4 FTE to enter the RIDE data into ICIS-NPDES.

o  Result is based on an entry time of 3-5 seconds per data element based on some time tests run by NY and Region 6.

o  This estimate includes existing WENDB data requirements.

o  This resource estimate does not account for data collection (or program implementation.)

o  DMR data entry accounts for the majority (over 90%) of these resources.

§  An enhanced DMR entry screen will be ready in the fall and will reduce the data entry time for large numbers of DMRs.

§  Capability for facilities to electronically submit their DMRs is scheduled for fall 2008.

Results of the RIDE Data Entry Estimate Model (as of 8/10/06):

FTEs/yr / Assumption / Nat’l / DE / UT / NE / OK / NY / GA / AR / MS / IA
Low estimate / 3 sec/ element / 2.4 / 0.07 / 0.4 / 0.8 / 1.9 / 2.3 / 2.3 / 2.3 / 2.3 / 3.4
High estimate / 5 sec/ element / 4.0 / 0.12 / 0.7 / 1.3 / 3.1 / 3.8 / 3.8 / 3.8 / 3.8 / 5.7

·  Current resources for WENDB entry into PCS today for Oklahoma is 3 FTE and 6 FTE for New York.

Data Collection

·  The Resource Group piloted a spreadsheet with several states to determine the status of collection for the RIDE inspection elements.

·  Four categories of collection status were identified:

1.  collected electronically,

2.  collected in paper format,

3.  not collected by the state but the facility maintains the information on site, and

4.  not collected by the state and the facility does not have the information on site.

·  The Resource Group unanimously recommends to the full Expanded Steering Committee that this exercise be done for the full RIDE list.

o  A determination was not made on how many States need to participate to have results to adequately represent the national picture.

·  Initially this was a gap analysis, not a quantitative assessment of data collection resources. However, the group just began discussions yesterday on how to convert the findings to cost estimates.

o  The States on the workgroup want to know the total cost of the Policy, including program implementation, prior to the Policy being finalized. The Resource Group’s charge did not include resources for program implementation and was to focus on data entry and collection.

Resources for Batch States

·  The Workgroup has initial draft language regarding the difficulty in assessing resources for batch States at this time given the status of ICIS-NPDES development for those states.