Don't look down we are in the cloud… Page 3. 3. What is Cloud Computing? ○
Cloud computing is the delivery of .... Digital Signature Protections - Hashing ...
Cloud Computing and Data Management in the 21st Century By Ben Peters
Linko Data Systems, Inc. Pretreatment & Fats Oil and Grease Software www.Linkoweb.com
Don’t look down we are in the cloud…
2
What is Cloud Computing?
3
Cloud computing is the delivery of computing as a service rather than a product, whereby shared resources, software and information are provided to computers and other devices as a utility (like the electricity grid) over a network (typically the Internet).
Perspective This presentation:
4
–
Discuss areas in pretreatment that have potential to be made more efficient through cloud computing
–
Assumes Pretreatment regulations and procedures are in place.
–
Is about using technology to accomplish goals more efficiently.
Technology Benefits Reduced demand on internal IT resources. Enter data into system one time. Share existing data between organizations.
5
Pretreatment tasks Permitting IUs Sampling according to schedules Receiving sample results from labs and Industries Enforcing Violations Inspections Reporting
6
Communication is required
More tasks being added to some Pretreatment staffs FOG Programs - More inspections and records Stormwater - More inspections and records Dental - More inspections and records
7
Communication is required
Oh yeah….
“We don‟t have budget to hire any new people, so you‟re going to have to find a way to „Just get it done.‟”
8
Ways cloud computing can help
9
Reduce Manual Errors By Importing Samples and Results directly from the lab and IU‟s Schedules are tracked and synced with outlook calendars. Users are Notified of activities due and managers can see a dashboard of these items.
Sampling Requirements Sampling SOP’s Sample notes displayed on mobile devices COC# INDUSTRY: ADDRESS: CONTACT: MONITORING POINT: SAMPLING NOTES:
COC-19046 AmeriCan Co. (Permit#: 00075) 900 Howdee StreetLinkoland Robert Dunner (303) 555-9876 001 (Pretreatment system effluent past flume)
1001 Fisher Rd. -Sample flume inside Pretreatment Room SAFETY NOTES: Bring cones to divert traffic in parking lot. Also review confined space procedures prior to sampling. COMPOSITE SAMLE BOTTLE#: COC-19046-001 CONTAINERS: 1 1L Poly 4 Deg C LAB: in house BOD-5 and TSS BOTTLE#: COC-19046-002 CONTAINERS: 1 500ml Poly 4 Deg C LAB: in house Flash Point Nitrogen Ammonia as N
10
Devices in the field
11
Taking Tablet’s on inspections
12
•
All IU and FSE past and present permit and inspection data available on the cloud.
•
Allows for the gathering of photos that are directly attached to the inspections form.
•
Allows for the inspector to gather the authorized officials signature.
Inspection Devices Tablet PC
13
Reporting
14
Incorporates Information from Various Data Sources. Plant data, bio-solids data and others. Reports Meet Exact Requirements Consistent, Repeatable, Reporting Process gained by having all
Remote Flow Gathering
15
Continuous flow can be transmitted to internet site for constant monitoring.
Seattle, WA uses these type of devices to manage WWTP influent and focus crew manpower.
Flow
16
Grease Trap Sensors
17
Levels can be transmitted to internet site for constant monitoring. Sepsensor (based in Massachusetts) www.sepsensor.com
Bar codes for Haulers
18
Haulers – can‟t miss location
Data received at POTW will directly import based on exact bar code location not hand written address.
Eliminates need to re enter pumping manifests received by mail, fax or e-mail.
Going Paperless with the Cloud? EPA‟s CROMERR Rule applied to Pretreatment fits with Cloud Computing model. Accepting SMCR‟s though the Cloud
19
Who is Affected?
Regulated Industry
EPA
State, Tribe and Local Governments –
20
EPA Authorized Programs – Pretreatment Programs
Background of CROMERR
21
Stems from the Government Paperwork Elimination Act
First proposed August 31st 2001
Effective as of January 11, 2006
Goals of CROMERR
22
Reduced cost and burden for entities submitting and receiving documents
Reduces the likelihood of data entry errors
Improved reporting efficiency
Must be legally enforceable
Electronic Reporting
23
An automated exchange of electronic data between two or more organizations in a standardized format
Examples of Electronic Reporting Currently used in the cloud
24
Bank Transfers Tax Submissions California will be receiving municipal SSO Reports Electronically Alaska has an Electronic Reporting System for Fishery data
What Applies to Industrial Pretreatment
Guidance documentation can be found in section VI. –
25
Requirements for Electronic Reporting Under EPA-Authorized Programs
Actual regulation modifications can be found in Subpart D – § 3.1000 and § 3.2000
What Applies to Industrial Pretreatment
•40 CFR Part 3 is dedicated to CROMERR
26
What Applies to Industrial Pretreatment
27
Pretreatment Electronic Reports
IUs may submit the following reports: –
– – –
28
Baseline Monitoring Reports Pretreatment Standards Report Periodic Compliance Reports Reports Made By Significant Industrials Users
Electronic Reporting Process Industry
POTW
1) Collects Compliance Data 2) Enter Data Into System 12) Process Report/Data 3) Review Document Content To IU 4) Review Certification Statement 5) Sign Electronic Signature
11) Send Acknowledgement 10) Store Copy of Record 9) Valid Signer
6) Sends Secure/ Encrypted Document
8) Valid Electronic Signature 7) POTW Receives Report
29
Electronic Receiving System Requirements
30
Receiving system requirements in sections VI.E. and § 3.2000
Designed to maintain the enforceability of paper based systems
Following the requirements of Section VI.E
Integrity of the Electronic Document
Once submitted documents may not be changed without detection
Achieved through: – – – –
31
System Security – Deter internet hackers Access Control – Internal system security Secure Transmission – Encryption processes Digital Signature Protections - Hashing
Document Must be Knowingly Submitted
Provide evidence that the submitter knowingly confirmed the submission process. Send out of band acknowledgement of submission –
32
Record at least the date, time, contact and the address to where the acknowledgement was sent.
Opportunity to Review and Repudiate POTW
Submitter must be notified that their submission was received
Ensure the opportunity to review and repudiate their submission
POTW must identify process to address the repudiation of a record – Identify acceptable repudiation time period
12) Process Report/Data 11) Send Acknowledgement
10) Store Copy of Record 9) Valid Signer
8) Valid Electronic Signature 7) POTW Receives Report
33
Validity of Electronic Signature
34
Electronic Signature is a unique digital ID for a specific person Electronic Signature Device is software or a set of code which creates a unique and identifiable digital signature Most common forms of digital signature devices include: PKI (public key infrastructure) certificate and PIN. – VeriSign and Entrust are Third party PKI providers
Validity of Electronic Signature (Cont)
35
Verification of signature device owner prior to accepting electronic signature
Verification that the document is unchanged since the execution of the digital signature.
Must verify the signer has the authority to make such submissions
Understanding Act of Signing Industry
A prominently displayed statement that there are criminal penalties for false certification must be clearly visible at the place of signing
1) Collects Compliance Data 2) Enter Data Into System 3) Review Document Content 4) Review Certification Statement
36
Complete a Subscriber Agreement
5) Sign Electronic Signature 6) Sends Secure/ Encrypted Document
Example Certification Statement
37
Subscriber Agreement Subscriber must sign an electronic signature agreement document requiring the individual to:
Protect signature device from compromise – –
38
Do not share device information Do not delegate the use of such device
Be held legally accountable by an electronic signature
Acknowledgement of Receipt
POTW
System must Send outof-band acknowledgement of document receipt – –
39
Email sent to address on file Letter sent to address on file
Must store a record that an acknowledgement of receipt was sent
12) Process Report/Data To IU
11) Send Acknowledgement 10) Store Copy of Record 9) Valid Signer 8) Valid Electronic Signature 7) POTW Receives Report
Acknowledgement of Receipt
POTW
Common uses of out of band acknowledgements include: –
– –
40
Bank notifying you if personal information has been altered On line account registration notification Investment records have been modified
12) Process Report/Data To IU
11) Send Acknowledgement 10) Store Copy of Record 9) Valid Signer 8) Valid Electronic Signature 7) POTW Receives Report
EPA Approval Process
To participate, each IPP must submit an application to the EPA –
–
41
EPA has provided a CROMERR Check List Identify who and where to send application
EPA‟s Technical Review Committee (TRC) reviews receiving system
Application Requirements
42
Certify legal coverage of electronic reporting
Document receiving system
Systems upgrade schedule
Other information requested by EPA administrator
Summary
43
CROMERR enables Pretreatment Programs to receive electronic compliance reports from IUs
Requires a comprehensive application process
CROMERR sets rigorous standards for electronic document receiving systems.
Additional Resources Contact Mrs. Evi Huffer at the Office of Environmental Information within EPA:
[email protected] Online Copy of Rule is available: http://www.epa.gov/fedrgstr/EPAGENERAL/2005/October/Day13/g19601.htm
Ben Peters can be reached for comments and questions at:
[email protected] or 877-546-5699
44
