electronic data systems - nerpca · 2019-10-28 · potw submits a program modification plan to its...

© 2019 Aquatic Informatics Inc. 11

Electronic Data SystemsImplementing an Electronic Self Monitoring Reporting System

Rich PrinsterLinko Technology

Matt SantellaMarlborough Water and Sewer Dept

21st Annual New England Pretreatment

Coordinators Workshop


A Case Study for Electronic Reporting

● Review of the CROMERR

● Why eReporting made sense for Marlborough

● The SMR submittal process before eReporting

● Implementing LinkoExchange

● The SMR submittal process using eReporting

● Outcomes


CROMERR Compliant Reporting

• Cross Media Electronic Reporting Rule

• Legally defensible electronic document collection

• Notify State or EPA Approval Authority along with CROMERR Program and National EPA Pretreatment Program


Steps for CROMERR Approvalhttps://www.epa.gov/sites/production/files/2018-05/documents/cromerr_potw_1.pdf

https://www.epa.gov/sites/production/files/2018-05/documents/cromerr_potw_1.pdf


5 Steps for CROMERR Approvalhttps://www.epa.gov/sites/production/files/2018-05/documents/cromerr_potw_1.pdf

1. POTW notifies its state or EPA Approval Authority of the intent to receive electronic reports under

its approved pretreatment program. POTW also notifies CROMERR Program ([email protected])

and National EPA Pretreatment Program ([email protected]).

2. POTW verifies that no local statutes exist that might conflict with statutes in place at the state or

territorial level establishing the legal validity of electronic signatures. The majority of U.S. states

and territories have adopted the Uniform Electronic Transactions Act (UETA) or their own

variations to establish the legal validity of e-signatures.

3. If needed, the CROMERR Program reviews and can also help draft POTW’s CROMERR

technical documentation to determine if the planned approach is CROMERR-compliant. a. If a

review is needed, the CROMERR Program notifies POTW and Approval Authority if the planned

approach meets CROMERR requirements. If the review generated comments, the CROMERR

Program works with POTW and/or its vendor to revise the planned approach until it is

CROMERR-compliant.



5 Steps for CROMERR Approvalhttps://www.epa.gov/sites/production/files/2018-05/documents/cromerr_potw_1.pdf

4. POTW submits a program modification plan to its Approval Authority which addresses how the

planned electronic reporting complies with relevant program management requirements outlined

under 40 CFR part 403. This can occur in parallel with Step 2 above, or – in certain cases – Step

2 is not performed. a. POTW works with its Approval Authority to revise program modification

plan as needed until it meets 40 CFR part 3 program management requirements.

5. The Approval Authority makes the final determination regarding POTW’s plans for electronic

reporting. Determination is typically communicated informally because approval to implement

electronic reporting is not a significant program modification under 40 CFR part 403.



Why eReporting made sensefor Marlborough

● Pretreatment Coordinator monitoring

○ 15 Permitted Significant Industries

○ 20 Permitted Non-SIU with samples

○ Approximately 300 FOG Generators

○ Approximately 40 Dental Offices

● Manage Marlborough along with Northborough

● I&I Responsibilities


Submitting Paper SMR

• Mail in

• Deliver in person

• Users are experienced and submitted complete reports

• Wouldn’t notice violations

• Double submittal for EPA + 20 Local Limits

• Industry didn’t send SMR for over a year with massive violations

Industrial User SMR Submittal Process


Receiving Paper SMR

• Enter into software

• Every lab has a different form- search for info

• Filed 3 years of reports in office and archive previous reports in storage

• Violation procedure


Implementing LinkoExchange

● CROMERR approval process

● Configure Industry Reports

● Train IPP Staff on LinkoExchange Module, Authority Portal and Industry Portals

● Train IPP staff on rolling out to Industries

● Timeline

High Level Overview


Implementing LinkoExchangeThe CROMERR Approval Process

From: Matthew Santella [mailto:[email protected]]Sent: Friday, July 13, 2018 11:42 AMTo: Pimpare, Justin <[email protected]>Cc: CROMERR <[email protected]>; Cromerr POTW Request <[email protected]>; [email protected]: CROMMER Certification

To Whom It May Concern;

As the IPP coordinator for the City of Marlborough DPW I would like to request authorization to electronically receive reports for our pretreatment program. We will be using the LinkoExchange program as a CROMMER compliant COTS solution. I would like to start using the program sometime in August or early September of 2018. We do not have any regulations in the City of Marlborough ordinances preventing electronic signatures.

Sincerely,

Matthew SantellaIPP and FOG Inspection CoordinatorWater and Sewer DepartmentCity of Marlborough135 Neil StreetMarlborough, MA 01752(508) 624-6910, ext. 33405Cell (774) [email protected]

mailto:[email protected]







Implementing LinkoExchangeThe CROMERR Approval Process



Met with Kellie - 2 hour sessions

• Data Prep and clean up

• LinkoExchange Samples

• Set up Industries with signatories

• Test samples

Configuration of Industry Reports

• Import

• Repudiate

• Translate



● Configure Industry SMR Report Templates

○ Define each report’s Effective Date (when the report will be available to Industries)

○ Set required report documents (Lab Analytical, COC, QA/QC, Wastewater Flow Rate, etc.)

○ Set required Certifications per report that require Signatory’s signature

● Configure any Non-SMR Report Templates (such as Annual Surveys)

● Assign Industry Report Templates to applicable Industries



● Train IPP Staff on LinkoExchange

○ Training on setup and use of Authority Portal

○ Training on setup and use of Industry Portals

○ Training on setup and use of the LinkoCTS> Modules > LinkoExchange Module

● Available Materials

○ LinkoExchange Authority Userguides



● Train IPP staff on rolling out to Industries

○ Train the Trainers - training session

○ Materials available for IPP staff

■ LinkoExchange Train the Industry Users SOP (Word DOC)

○ Industry Users Training Materials

■ LinkoExchange Industry User Video Training Series

■ LinkoExchange Industry Userguide

■ LinkoExchange Lab EDD Userguide (with video examples)

● LinkoExchange Lab EDD Example (multi-tab spreadsheet)


Submitting SMRs Using eReporting

• Industry User imports Lab Sample data

• Industry User uploads required supporting documentation (Lab Analysis, COC, QA/QC, etc.

• Industry User Compiles SMR Report package• Industry Signatory signs and submits the

SMR Report Package• System sends email notifications to IU

Signatory and Authority of the successful report submittal



Report Summary

• Ensures Report is Complete

• Summarizes Sample

Compliance


<Screenshot of submittal page with signatory line>

Review and Sign

• A Summary is provided to

ensure the Signatory is informed

• Only the Authorized Signatory

can Sign and Submit the Report



Electronic

Signature


Industry User receives email

confirming report submission


Receiving SMRs Using eReporting

• Authority will receive system generated email that a report has successfully been submitted

• Authority User logs into their LinkoExchange Authority Portal to review the submitted IU SMR report package

• Authority User sends reviewed SMR report to the queue to be imported into LinkoCTS software

• Within LinkoCTS, Auth Users performs compliance on imported reports and samples


eReporting Notice

Name of

Signatory

Authority receives email

notification of report

submittal

Electronic

Signature


Submission Review

Review Submission

• Audit Trail

• Provide Comments

• Queue Data for Import and

Send

• Print Copy of Record (COR)


Data Import

Create Violations

• Late SMRs

• Sampling Violations

• Track Enforcement

• Report


Lessons learned and Outcomes


Concerns Going In

● Older Industrial User operators learning new computer system

● How to train the Industrial User operators

● Will this really work?

● Typical computer glitches with email/internet


Positive Results

• It really is Faster! No data entry, No data entry mistakes

• Facility Training- Works best when the report is due and real data is used

• No more hunting for data on different Lab forms

• Consistency with Violations

• Address specific Instance

• Ensure Accurate Reporting


Negative Results

• Some Labs didn’t want to create the Import Spreadsheet

• Some charged IU for custom form

• One just wouldn’t do it

• Had to clean up inconsistent parameter names

• Had to set up templates for TTO

• Not sure if Reports have to be printed for PCI


Outcomes (So Far)

Industries

• Like submitting electronically once they are familiar with the steps

• Faster

• Like visibility with report elements and violations

Authority

• Faster

• Elimination of data entry errors


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QUESTIONS?

electronic data systems - nerpca · 2019-10-28 · potw submits a program modification plan to its...

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