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1 Questions and Answers from Compliance Monitoring Data Portal (CMDP) Webinar for Drinking

Water Utilities and Utility Associations

Questions and Answers from Compliance Monitoring Data Portal (CMDP)

Webinar for Drinking Water Utilities and Utility Associations

February 18, 2015

Please note: The follow questions and answers represent the most current thinking in regard to

the CMDP requirements and design. Additional requirements, or adjustments to existing

requirements, will be identified and evaluated in the course of development sprints and during

pre-production releases planned to occur between May and December 2015.

1. How many roles may an individual have? I work in a tribal environmental lab with only two

FTE.

CMDP roles will be hierarchical such that a user may have more than one role. In addition to sponsoring others in your lab organization to obtain access to the CMDP, your Lab CMDP Administrator will be able to perform all other roles on behalf of the lab: as a Certifier/Submitter to sign and submit files, as a Reviewer to review files that have been prepared by your lab, and as a Preparer to complete web forms or fill out data templates. A Certifier/Submitter would not have administrative functions, but would be able to perform as a Reviewer and Preparer. A Reviewer could not certify or submit, but could prepare web forms or populate data templates. For a small lab with only two staff, it would be advisable to have both individuals serve as CMDP Administrators.

2. If a utility submits a request to the state to approve an alternative criteria for TOC removal,

and that request is approved post monitoring period, how will the data be updated in CMDP

to reflect the change?

Changes to the utility’s treatment technique should first be documented in the state’s inventory

tables in its compliance database. These changes then will be updated in the CMDP’s relational

database at a frequency (e.g., every evening) determined by the state agency.

3. We may have cases where multiple entry points are reported, so will need ability to have

more than one point-of-entry in the Chlorine/Chloramine Entry screens.

We understand this requirement and can update this functionality in the CMDP during the

development sprints.



4. For all of the data (turbidity, chem, bact), is there the option for templates or uploads? Or

is it required to enter in data manually?

A user will be able to download locally a template for each of the sample types in question, and upload it to the CMDP. A user is not required to use the CMDP web forms designed for on-line manual data entry.

5. If a contract lab is utilized, will they directly submit data thru the CMDP or will the data be

sent to the PWS to review/certify? We are assuming our administrator will approve the

contract lab.

Your approval of the laboratory would occur prior to the laboratory registering with CMDP. The lab would send the file directly to the state and the PWS would get a notification that a copy of the file is available for them to see. 6. Will the monthly operational reports be entered into this system? Or will our state decide

this?

Yes, the CMDP will support all federally required operational sample types, including monthly

operational reports under the IESWTR and LT1 regulations.

7. We analyze the microbial samples by ourselves, but subcontract out VOC samples. Do we

have to enter the VOC data too?

Either your lab or the subcontracting (analytical) lab could report the VOC samples. If your lab

reports the VOC samples, then in addition to information about the water utility, the CMDP also

will require that your lab report information about the subcontracting (analytical) laboratory, to

ensure that the state primacy agency can confirm that analytical lab is using an approved method

and is certified in that method. If the subcontracting (analytical) lab not only performs the

analysis but also reports the VOC samples, then it will have to comply with CROMERR

requirements by signing an Electronic Signature Agreement (ESA) and electronically certifying,

signing and submitting each drinking water sample file to the state.

8. Can we use our log-in information and personnel that we use now for CDX pertaining to

UCMR?

To access the CMDP, you will need to register using the Shared CROMERR Services’ “Registration

and Account Management” service. More information on SCS will be provided prior to the first

pre-production release, which we anticipate occurring later this summer.



9. We collect over 200 BACT samples each month. We would have to input each sample

separately?

You would have a couple of options for reporting these 200 samples using the CMDP. One option

would be to download the microbial rule template (available on the CMDP dashboard), enter the

results on your local system, and then upload the file containing the batch of 200 samples all at

once, with the validations run against each record individually. Another option would be to enter

the sample results as a batch file, using the CMDP web application. As a time-saving feature

built into the web forms, the sample meta-data elements (data about the PWS, e.g., the sample

location, monitoring period, and sample type) would be auto-populated based on user-defined

settings for the initial individual sample entry for the batch.

10. How much flexibility for the different roles will there be? Can the same individual have

different roles (administrator, preparer, etc?) Are the relationships between preparers /

reviewers, etc. set up in advance?

CMDP roles will be hierarchical and are established in advance when a user registers with Shared

CROMERR Services (SCS) to use the CMDP to report drinking water sample results to states. In

addition to sponsoring others in your utility organization to obtain access to the CMDP, your PWS

CMDP Administrator will be able to perform all other roles on behalf of the utility: as a

Certifier/Submitter to sign and submit files, as a Reviewer to review files that have been prepared

by your utility, and as a Preparer to complete web forms or fill out data templates. A

Certifier/Submitter would not have administrative functions, but would be able to perform as a

Reviewer and Preparer. A Reviewer could not certify or submit, but could prepare web forms or

populate data templates, in addition to reviewing files submitted by others in your utility.

11. Will the PWS Profile be limited access to the PWS users only or will the Lab have access to

this as well?

In version 1.0 of the CMDP, as shown during the CMDP webinar, the Laboratory will have read-

only access to the sample meta-data, including sample point identification numbers and several

other data elements about the water utility. This information will be very similar to the

information provided by an existing web application used by several state primacy agencies,

called Drinking Water Watch, which contains the sample meta-data laboratories need, including

the monitoring schedules. For states that transition to SDWIS Prime beginning in 2017, the

monitoring schedules for the utility that are stored in SDWIS Prime also could be made available



to the laboratory from within the CMDP application, as read-only values which can be auto-

populated into web forms for data entry.

12. If a system already has a template approved by the state in excel for CFE/IFE, can that be

uploaded in the batch file upload?

Nonstandard (i.e., custom) templates will not be accepted by the CMDP. The CMDP will accept

the standardized templates available via the CMDP, or LIMS data files from laboratories that have

been converted into XML format based on the CMDP XML schema.

13. Some changes to the PWS Profile should be available at the PWS level (for example e-mail

and address).

Administrative contact information about the PWS will be included in the PWS Profiles.

14. In order to upload a batch, PWSs would need to create a report that generates a .csv from

their particular LIMS/database. The .csv must include all elements required in the microbial or

chem templates. Is that correct?

Correct. The PWS or lab would need to generate from its LIMS/database a file that contains all

the data elements in the specified XML schema definitions, which will be provided by EPA to the

states, laboratories and utilities as part of their transition to the CMDP. The LIMS file must

include all of the federally required data elements that appear in the web forms and the

templates.

15. What is the role of the State? For ex, the utility or lab will enter data into this system and

approve it. Then it goes to the state? Who "houses" or controls the data - the EPA or individual

states?

The role of the state as the primacy agency is to receive the data from the CMDP only after the

utility or lab electronically signs and submits the file, (the e-file having the same purpose as a

paper copy of the same information). Each individual state will control the data it receives. EPA

will not have user roles or access to the CMDP database.

16. Will each individual TCR site and results be entered into the system?

TCR sample sites will be migrated into the CMDP relational database from the state compliance

database as part of each state’s transition plan. These reference data will be used to auto-



populate the sample location, name and ID numbers in the web forms that labs and utilities use

for reporting individual samples or batch files.

17. In other words, our subcontract lab needs to be CDX user/CMDP user too!

A subcontracting laboratory would need to have access to the CMDP if it is serving as the

reporting lab as well as the analytical lab.

18. Will there be an area inside the quarterly TOC available to report SUVA as an alternate

method?

Yes.

19. Are the majority of the state agencies aware of the CMDP and how much time do the states

have to implement this reporting process with their utilities?

All states have been made aware of CMDP through a variety of mechanisms, including several

ASDWA conferences.

20. Also, can the preparer / reviewer relationship be set up between a PWS and a contracted

laboratory (within the PWS or at a third party)? Or is the preparer / reviewer relationship only

within a user type?

The Preparer/Reviewer relationship is only within a user type. 21. Will the EPA be responsible for data retention requirements, or will utilities be required to

keep paper copies of submissions?

Utilities will not be required by EPA to keep paper copies of submissions, but a state agency might

still require paper copies. It would be best to confirm with your state agency once it has begun

a transition to the CMDP.

22. I would think that PWS' would want to be in control of the PWS profile information and be

the only entity that makes changes to that information.

A PWS will be able to use the CMDP to inform the state of any changes to PWS profile

information. The state will independently confirm a change with the utility, and update its



inventory tables in its state compliance database. By default, the CMDP Profile data elements

will automatically be updated to reflect the changes in the state compliance database.

23. Will all of the states have a chance to comment on the templates in the CMDP required to

comply with the new scheme?

Yes.

24. What's the time frame between each level?

No time frame between each work flow stage will be built into the CMDP application; timeframes

will depend on the user’s availability to interact with the software as part of a work flow. To

avoid reporting violations, however, an entire work flow process, including electronic signature

and submittal, should occur within the time frames required by state drinking water regulations.

25. Will utilities have the capability to generate a report of what was reported for a specific

month? Will there be a function to print out a report of the data submitted?

For version 1.0, a utility will have a “Maintenance View,” accessible via the CMDP user interface,

which summarizes the status of all sample results files entered into the CMDP to date. However,

we will investigate during development of version 1.0 whether the contents of this view can be

downloaded as a report.

26. Will it be possible to set up more than one level of review? For example, can a large utility

first have a departmental manager review a file, and then a compliance officer (or something

similar) review it again before moving on to certification?

For version 1.0, the CMDP will feature one Reviewer within a CMDP workflow, though more than

one Reviewer may be working concurrently with the CMDP. Before the CMD file is certified and

submitted, it may be downloaded locally and e-mailed to, or otherwise shared with, other

reviewers within your organization, in addition to the Reviewer with authorized CMDP access.

27. Suggestion for all screens: indicate which fields are mandatory with an asterisk ' * '.

EPA agrees that the web forms should clearly indicate which fields are mandatory.



28. Can the submittal of this data result in a system violation? Will there be a field in the CMDP

to view violations?

The data submitted through the CMDP can result in a system violation as determined by the state

primacy agency, just as with data submitted on paper or using another electronic reporting

system. There will not be a field in the CMDP to view violations as determined by the state,

because that functionality is outside the scope of the CMDP.

29. I noticed the earlier question about corrected data. Although spotting validation issues is

important and useful (and should hopefully cut down on the need to correct data), there also

needs to be a clear path for correcting incorrect data that made it all the way through to

submission. This is true for all instances, but especially for third party submissions since there

doesn't appear to be any way for a utility to approve a laboratory submittal. Is a clear

correction protocol / process being developed?

For errors that appear in the data submitted to the state system, there will be two levels of

validation (error detection). The first level will occur in the CMDP and will address the most

common kinds of errors related to character, format, range, value, presence and other kinds of

data checks. The CMDP will support three ways to correct data at this stage of the reporting

process, once the user can see the validation report that identifies the errors: (1) delete the file,

make the corrections locally, then resubmit via the CMDP to a Reviewer; (2) resubmit only the

corrected records as a new file, while allowing the original valid records to be sent to the

Reviewer; and, (3) correct the errors while interacting with the system during the same user

session, and then send the records to the Reviewer.

Second-level validations is already are built into each state’s compliance system, e.g., SDWIS

State, and similar validations will be built into SDWIS Prime. Further, each state currently has its

own protocol for making corrections based on its existing system, and by extension, EPA expects

these state-specific protocols will be applied to SDWIS Prime. SDWIS Prime will feature

standardized compliance decision support functionality for state primacy agencies which will flag

potential (“candidate”) violations based on federal requirements. As with their current

compliance systems, however, each state compliance officer will make the final compliance

decisions based on the sample results and state primacy agency protocols.



30. Does the certifier have to be the Operator of Record?

Each utility will have a CMDP Administrator, who will designate utility users to access the CMDP

for that utility, including the Certifier/Submitter role. That person might be an employee of the

utility, but not necessarily the Operator of Record; it can vary by utility organization. Whomever

serves as Certifier/Submitter for a utility, however, must sign an Electronic Signature Agreement

using Shared CROMERR Services (SCS) and understand the legal obligations of electronic

signature.

31. Following up on the questions about who houses / owns the data, I think that needs to be

more fleshed out. I recognize you're saying that existing state/EPA/utility/laboratory

relationships won't change, but it isn't clear on whose servers the data will reside on and who

has ultimate control of it. Is it EPA? The States for systems within that state? Does it change

during different steps within the process? Given the differences in state and federal

requirements for data retention, public / not-public information, and all sorts of other issues,

that seems like it should be clearly defined up front and an opportunity to comment on it

provided.

As noted in the CMDP webinar, the CMDP is a cloud-hosted web application and database which

will support existing reporting relationships among authenticated and authorized state,

laboratory and water utility users. EPA will not be a CMDP end user. EPA’s role, other than to

lead system development in coordination with state primacy agencies, is to provide operations

and maintenance technical support for the CMDP system. The CMDP will reside on servers that

are physically located in a facility owned and operated by a third-party cloud provider, e.g.,

Amazon Cloud. Each state primacy agency will have access only to the electronically signed and

submitted data for which it is the intended recipient, which will reside in its own discrete portion

of the CMDP database, and which will be entirely and securely partitioned from the data

submitted to other states. A laboratory or water utility user will have access to the CMDP to

report sample results data and also to view historical data, i.e., data it already has electronically

signed and submitted.

32. As of now, which states are involved with CMDP?

There are 10 states assisting EPA with CMDP development, as part of the Data Portal Work Group

(DPWG). They are: Connecticut, Indiana, Kansas, Louisiana, New York, Ohio, Oklahoma, Oregon,

Pennsylvania, and Texas. Other states will be able to comment on the CMDP when it is released

into the pre-production environment prior to user acceptance testing.



33. What is the process for submitting corrected data?

The workflow for submitting corrected data is essentially the same as for the original data set. In

the example we discussed during the CMDP webinar, if a Preparer attempts to enter 1000 sample

results (presumably using a data template for batch upload, or LIMS) and 998 of them are valid,

then the valid results could be submitted to the Reviewer, while the Preparer would use the

validation report to identify the two that are not. The Preparer then would create a new CMD file

for the two sample results that were corrected, and if they determined to be valid, send the

results on to the Reviewer as a separate file. Please note that some states do not accept partially

valid batch files; in this case, the lab or utility would be required to start over the entire process

to report the 1000 samples results. In those states, the user would delete the initial file, and

generate locally a new file containing 1000 samples with the corrected errors. Please note that

the CMDP also will feature a third option, which is the ability to make corrections to erroneous

data while logged into the system within the existing workflow. In this example, for the two

errors that are detected, the user could make corrections to the individual samples within the

batch file, save the updated file, and then continue the work flow by sending the 1000 valid

sample results to the Reviewer. This latter method will ensure that users who need to log out of

the system to perform other work can return later to complete the work flow without having to

memorize all of the sample meta-data (sample points, sample types, monitoring periods)

associated with any corrected sample results.

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