Utah Division of Drinking Water & the EPA Compliance Monitoring Data Portal

by Rachael Cassady

The Utah Division of Drinking Water (UDDW) began using the EPA Compliance Monitoring Data Portal (CMDP) production environment in February, 2017. UDDW now receives coliform and some chemical data from the largest private lab in Utah, through the CMDP. The use of the CMDP has already saved significant UDDW staff time and noticeably reduced data file errors.

UDDW participated in early testing of the CMDP and was able to prepare our certified labs to move towards the CMDP. We were fortunate to coordinate with the state’s largest private lab to test the CMDP and prepare to use it in the production environment as soon as possible.

The CMDP is an excellent tool for UDDW. The previous process for receiving electronic data was cumbersome for the labs and difficult for UDDW staff to manage. We previously did not have an interfacing application with SDWIS that allowed for automatic transfer of data. Instead, labs submitted csv files to us over email. These files were uploaded to Lab to State, then migrated to SDWIS using XML Sampling. This process was problematic because our Lab to State is not outward facing, forcing UDDW staff to manage the error reports and data fixes. By default, we created the perfect environment for the CMDP because our old process forced UDDW staff to constantly wrestle with lab staff to transfer data into SDWIS without errors. Even today, we still struggle with the time it takes for UDDW staff to deal with Lab to State and XML Sampling error reports.

The CMDP is the solution to our electronic data transfer problems. It allows the labs to perfect the data schema, fix their own errors, certify the accuracy of the data, and requires very little UDDW staff time and effort. The table below shows XML Sampling errors with CMDP files, compared with the old process, in just one week of reporting:

How can we not use the CMDP? In one week of reporting, UDDW staff dealt with less than 1% errors in the CMDP files and over 20% errors in our csv process files. That is a stunning difference. The handful of CMDP errors we observe are simple fixes, such as monitoring period associations. In comparison, the csv errors are critical errors, such as no results, no units of measurement, and complete file rejection.

The CMDP has reduced our staff involvement in data transfer, reduced the count of data errors, and saved staff time. Of course, there are minor issues and things to address along the way. EPA has provided UDDW assistance in learning how to manage our Shared CROMERR Services (SCS) users, and in correcting small issues such as updates to method analyte pairings. We are pleased with the technical support service the EPA CMDP team provides.

Transition to the CMDP was not difficult. It took a little over a week of working with EPA and their contractor to test our data uploads through the DSE, and to be certain that everything was connected. Once the DSE was functional and we had our production environment CMDP link, our large private lab was able to electronically submit coliform samples. Now it regularly submits routine, repeat, and triggered coliform samples (with chlorine residuals) through the CMDP. It also submits individual analytes such as nitrate and arsenic, and our disinfection byproducts analyte group. It uses a LIMS system (Element by Promium) that it did not need to modify; it exports to Excel, and with some code, changes it to the correct XML schema.

The question remains, how will UDDW get other labs to start using the CMDP? Utah does not have an electronic reporting rule, and still receives some data in hardcopy that must be hand entered. Many of our smaller labs are accustomed to the old csv schema and have never created XML files. On the surface, this appears to be a severe stumbling block to our goal of implementing the CMDP state wide. However, the CMDP provides some key elements that our old electronic data process does not:

• With the CMDP, the labs control their error reports and certify their data electronically.
• The labs that use the CMDP can tell their customers that their compliance data is reported on the same day it is generated. This is important because UDDW is running compliance faster; we send out notices of violation within hours of the reporting window closing. Our water systems need the immediacy the CMDP provides.
• Most importantly, with the CMDP, the labs are not forced to communicate back and forth with UDDW staff in the laborious and miserable process of fixing errors in their data files. Less human interaction is priceless for all parties involved.

In order to encourage the other labs in the state to use the CMDP, we plan on working with them individually and starting small. We are targeting the technical IT groups at each lab and showing them the Excel templates from the CMDP, using scrubbed XML files from our large private lab. Our plan is to baby-step our labs into the CMDP, beginning with coliform data. We have noticed that each lab is different in how we need to approach them about using the CMDP; some require more assistance than others. It will be useful when more labs across the country have adopted the CMDP and there is a larger knowledge base to help all types of labs, large and small.

The news that the state’s largest private lab is using the CMDP has spread among water systems in Utah. Smaller labs will need to adopt the CMDP to stay competitive in a compliance world that is now very strict, precise, and requires less human intervention than ever before.

The CMDP came to us at pivotal time and we are lucky that we are in a position to adopt the CMDP quickly. We plan to build on the compliance success that the CMDP is providing us, and hope to move towards our public water systems using it as well. We look forward to working with EPA and other CMDP states to continue the CMDP development.

Rachael Cassady is an Environmental Program Manager at Utah DDW. She may be reached at rcassady@utah.gov