Region 8 GUIDANCE FY-2012
Performance Partnership Agreements
Environmental Protection Agency
Office of Enforcement, Compliance, and
Environmental Justice
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
May9, 2011
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TABLE of CONTENTS
Introduction
1. PERFORMANCE PARTNERSHIP AGREEMENT REQUIREMENTS
A. Maintain Core Programs
B. Maintain National Databases
i. Safe Drinking Water Information System (SDWIS)
ii. Permit Compliance System (PCS)/lntegrated Compliance
Information System(ICIS)-National Pollution Discharge Elimination
System (NPDES)
iii. Air Facility Registry System (AFS)
C. Accountability Measures
D. Exchange Network
i. ICIS-NPDES
2. FY2012 REGIONAL PRIORITIES AND PPA AREAS OF EMPHASIS
A. Regional Priorities
B. Environmental Justice
C. Inspection Projections
D. Compliance Assistance
E. Facility Watch List
3. OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE (OECA)
PROGRAM PRIORITIES. ENFORCEMENT INITIATIVES (2011-2013). CROSS
CUTTING STRATEGIES (FY-2011-FY-2015). SIGNIFIGANT CHANGES FROM
FY-2011
A. Program Priorities
i. Taking Action On Climate Change
ii. Improving Air Quality
iii. Assuring The Safety Of Chemicals
iv. Cleaning Up Our Communities
v. Protecting America's Waters
vi. Expanding The Conversation On Environmentalism And Working
For Environmental Justice.
vii. Building Strong State And Tribal Partnerships
B. Enforcement Goals FY-2012
i. Aggressively Go After Pollution Problems That Make A Difference
In Communities
1. Clean Water
2. Clean Air
3. Climate And Clean Energy
4. Protect People From Exposure To Hazardous Chemicals
ii. Reset Our Relationship With States
1. Shared Accountability
2. Strengthened Oversight
3. Establish New Model For Shared Accountability And
Strengthened Oversight, Starting With Water
iii. Improve Transparency
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C. Enforcement Initiatives (2011 through 2013)
i. Keeping Raw Sewage And Contaminated Stormwater Runoff Out
Of Our Waters
ii. Cutting Animal Waste To Protect Surface And Ground Waters
iii. Reducing Widespread Air Pollution From The Largest Sources,
Especially, The Coal-Fired,, Utility, Cement, Glass and Acid
Sectors
iv. Cutting Toxic Air Pollution That Affects Communities' Health
v. Assuring Energy Extraction Sector Compliance With
Environmental Laws
vi. Reducing Pollution From Mineral Processing Operations
D. Cross Cutting Strategies in the FY-2011 through FY-2015 Strategic Plan
i. Expanding the Conversation on Environmentalism
ii. Strengthening State, Tribal and International Partnerships
iii. Working for Environmental Justice (EJ) and Children's Health
E. Significant Changes From FY2010
i. Clean Water Action Plan
ii. New Wetlands Program
iii. Oil Spills Prevention
iv. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
Program
4. PROGRAM OVERSIGHT
5. PROGRAM SPECIFIC GUIDANCE
A. Clean Air Act (CAA)
B. Clean Water Act (CWA)
C. Safe Drinking Water Act (SOWA)
D. Resource Conservation and Recovery Act (RCRA)
E. Toxics Substances Act (TSCA)
F. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
G. Comprehensive Environmental Response Compensation and Liability Act
(CERCLA)
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APPENDIX
Appendix 1 FY2012 OECA National Program Guidance
Appendix 2 Enforcement Accountability Measures
Appendix 3 Memo from Mike Stahl regarding Data Quality Strategy and Projects
Appendix 3a Enforcement and Compliance Data Quality Strategy
Appendix 4 Compliance Assistance Memorandum
Appendix 5 Memo from Mike Stahl regarding Compliance Assistance Outcome
Measures
Appendix 6 Region 8 Enforcement Oversight Protocol Revisions April 2011
Appendix 7 PCS Policy Statement including WENDB Elements
Appendix 8 December 28, 2007 Addendum to the PCS Policy Statement
Appendix 9 40 CFR 123.45
Appendix 10 RIDE Elements
Appendix 11 AFS Business Rules
Appendix 12 AFS Minimum Data Requirements (MDR's)
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Introduction
EPA's national enforcement and compliance assurance program is multi-media in scope
and breadth. The national program maximizes compliance with ten distinct federal
environmental statutes through the use of compliance assistance, incentives, monitoring,
and civil and criminal enforcement. OECA implements a total of 28 separate program
areas dealing with prevention and control of air pollution, water pollution, hazardous
waste, toxic substances, and pesticides. The statutory and regulatory requirements of
these programs apply to a diverse universe of regulated entities. The majority of the
work in the FY-2012 NPM is accomplished under the strategic goal "Compliance and
Environmental Stewardship" in the draft FY 2009-2014 EPA Strategic Plan.
The NPM describes the key actions needed to accomplish this goal as proposed in the
draft EPA 2009-2014 Strategic Plan Change Document
(http://www.epa.gov/ocfo/plan/pdfs/strategic plan change document 9-30-08.pdf The
Office of Enforcement and Compliance Assurance (OECA) has released their National
Program Managers (NPM) Guidance document covering Administrators priorities, goals,
initiatives and significant changes from the FY-2010 NPM guidance. This is included in
the ECEJ Appendix 1. The NPM Guidance can also be located at the following website:
http://www.epa.gov/finance/npmguidance/index.htm.
The NPM and Region 8 PPA guidance outline national program priorities and activities
for enforcement and compliance regulatory programs for FY 2012. The guidance
documents are prepared to assist the state in the development of an effective
Performance Partnership Agreement with Region 8. This document includes updated
information regarding performance commitment requirements, Regional and National
priorities, EPA Administrators' priorities, Program Oversight activities, as well as core
program guidance.
a. Performance Partnership Agreement (PPA) Requirements
The following section contains information regarding the maintenance of Core
Programs, National Databases and Accountability measures that must be included in
submitted PPA's.
A. Maintain Core Programs
The state agency must maintain and implement the core programs, as
required by the federal and state statutes and rules, and as reflected in
program authorizations and other formal agreements between EPA and the
state.
The FY2012 NPM Guidance provides a detailed, statute specific
core program description.
The State may also describe standard commitments in the
Agreement that reflect core program activities (e.g. development of
the Compliance Monitoring Strategy of the air program). Additional
State specific language may be discussed during the negotiation of
the Agreement, in accordance with the results of oversight results.
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B. Maintain National Databases
The state agency must maintain national databases. This includes entering
required data elements in a timely manner; performing appropriate data
quality assurance and data validation tasks; and assuring timely, accurate,
and complete information is available for retrieval by State and EPA staff and
managers. The existing Final Enforcement and Compliance Data Quality
Strategy and Description of Data Quality Strategy Implementation Plan
Projects are included as Appendix 3 and 3a.
The Office of Compliance, Enforcement Targeting and Data Division, is
developing a comprehensive Data Quality Strategy that will improve upon the
disparate approaches previously used in order to provide a strategic vision
and implementation schedule to assure that enforcement and compliance
data can be used as an effective tool to manage our program and report on
our accomplishments. This will become effective when completed.
Additional details on specific activities to implement this strategy will be
provided to State Agencies as they become available. Key elements include:
Identification of key enforcement and compliance program data
fields.
Developing standards for verification and validation of the
accuracy of data being entered into key data fields in each
database
Ensure full implementation of the Watch List project reporting by
regional offices along with timely and complete reporting of
necessary compliance and enforcement data to national
databases
Periodic random data audits and targeted data clean-ups
Updating guidance on the input and use of certain key data fields
in each database, including identifying where underlying media
specific program guidance needs to be updated and/or revised
Ensuring accurate data entry into legacy systems by state
personnel.
Suggested PPA Language:
"The State commits to entering required data into regional and national data
systems so that federally required data fields are timely, accurate, and complete
pursuant to definitions, guidance, and policy."
a. Safe Drinking Water Information System (SDWIS)
Ensure all enforcement actions are linked to violations in SDWIS.
Exceptions to the list of currently identified orphan enforcement
actions are:
S/E IB Compliance Meeting Conducted
S/E 1C Tech Assistance Visit
S/E OY Variance/Exemption Issued
S/E OZ Turbidity Wavier Issued
S/EFE Boil Water Order
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S/E FO Administrative Order with penalty )failure to
comply with a previously issued AO (S/E FL)
Ensure any PWS s lacking lat/long and mad code data, have
been identified, corrected and submitted for the quarterly
reporting process to update SDWIS/Fed.
Ensure new regulatory violations are tracked and reported to
SDWIS the quarter after occurrence. When draft guidance is
issued, States should start working on tracking and implementing
reporting requirements.
To ensure that all regulatory rules are tracked and reported,
states should use the most current versions of the SDWIS
product. Currently SDWIS/State 2.3 and SDWIS Fed 3.2. FedRep
will only support SQL and Oracle. Foxpro is no longer supported.
Review, identify and correct in SDWIS all violations which should
have return to compliance designation.
Pursuant to SDWA guidance, ensure that all violations,
enforcements and samples data are reported the quarter
following their occurrence to SDWIS/Fed.
States should report compliance assistance visits on a quarterly
basis to SDWIS (a code under sanitary surveys). There is now a
code for follow-up visits for formal enforcement that should be
reported as they occur.
b. Permit Compliance System (PCS)/ICIS-NPDES
EPA will evaluate the States on how they maintain their PCS
database for data integrity, completeness, timeliness and
accuracy on all required Water Enforcement National Database
(WENDB) data elements (for those states still using PCS)
(Appendix 7) and the minimum data element specified in the
December 28, 2007 Addendum to the PCS Policy Statement
(for those states migrated to ICIS-NPDES) (Appendix 8) for state
inspections, enforcement actions, and Discharge Monitoring
Reports (DMRs); as well as completeness for all permit facility,
permit tracking, locational data, pipe and flow data.
During FY2012 all states must adhere to all processes and
requirements outlined in the PCS Policy Statement, including the
December 28, 2007 Addendum for those states that have
migrated to ICIS-NPDES (Appendix 8). .
Because the PCS database is being replaced by the new
ICIS/NPDES database, EPA has recommended that States
clean up PCS missing or inaccurate facility and pipe-level
information in addition to the above evaluation criteria. EPA
Headquarters has identified 34 facility WENDB data elements
that are to be entered into PCS for every active permit (the
information to populate these fields is obtained from individual
NPDES permit applications and their Statement of
Basis/Rationale) (Appendix 7). EPA is working with each State
to complete this effort. To facilitate the States in their data
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cleanup, a Data Migration Guidance Document has been
compiled by Headquarters that will guide the States on how to
cleanup their PCS data. Also, Headquarters has weekly ICIS-
NPDES Cleanup Calls for the States that are cleaning up their
PCS data to answer any questions or concerns the States are
having.
c. Air Facility Registry System (AFS)
Data is an integral part of the CAA compliance and enforcement
program; therefore, it is essential that Regions and delegated
agencies enter complete and accurate information into the
national database in a timely manner. Complete, accurate and
timely data is necessary for EPA, delegated agencies and the
public to evaluate programs and institute corrections. A
complete list of MDRs as well as the CMS and HPV Policies,
can be found at the following website and in Appendix 12.
http://www.epa.gov/compliance/data/systems/air/afssystem.html
The PPA should include the following data related elements:
o States will provide complete, accurate, and timely data
consistent with the MDR's as well as the CMS and HPV
Policies.
o States will report the compliance results of all FCEs and
negotiated PCEs into AFS as soon as practicable after a
compliance determination is made.
o States will coordinate with EPA to ensure that CMS
sources are flagged in AFS for inspection, and to ensure
that high priority violations and associated enforcement
actions are correctly identified in AFS.
o States will report 100% of the stack tests and the results
(pass/fail) in AFS when a compliance determination has
been made.
o State will make appropriate corrections to AFS as
identified by the Regions or HQ's
Additional State-specific language may be discussed during the
negotiation of the Agreement, in accordance with results of the
Oversight assessments.
C. Accountability Measures
Region 8 anticipates that each State will adopt the performance measures
agreed to by EPA and ECOS. The enforcement and compliance assurance
outcome and output measures should be included in the Agreement.
Additional and/or alternative measures may be discussed during the
Agreement negotiation period. The enforcement accountability measures are
included in ECEJ Appendix 2.
D. Exchange Network
a. ICIS-NPDES
An Exchange Network data flow for ICIS-NPDES is partially
available. Partners can use the Exchange Network to submit
Discharge Monitoring Reports and permit data. Data flows are
currently being developed to handle inspections, enforcement
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actions, and all other NPDES data families. Those data flows
are expected to be ready in 2013 at which point all states will
need to migrate away from the legacy Permit Compliance
System (PCS). At that point, the Exchange Network will be
the only means of submitting NPDES information to EPA other
than manual data entry.
More information on this data flow including known barriers
and practical implementation advice is available at
http://www.exchangenetwork.net/exchanges/ICIS%20NPDES
%20flow%20implementation.pdf
b. States that are currently using the NPDES Permit Compliance
System (PCS) need to prepare to migrate to the modernized
data system, ICIS-NPDES. The batch data flow capability
from States to ICIS-NPDES through EPA's National
Environmental Information Exchange Network is currently
under development and is scheduled to be implemented in
three distinct releases.
The first release, scheduled for February 2011, will
provide functionality for the transmittal of Permit and
Facility information.
The second release, scheduled for January 2012, will
provide functionality for the transmittal of Inspection
information.
The final release, scheduled for March of 2013, will
provide functionality for the transmittal of remaining
NPDES data families to include Enforcement Actions,
Single Event Violations, and Program Reports.
c. Actively market and implement the use of NetDMR or other e-
DMR tools by permittees for the electronic transfer of
Discharge Monitoring Reports (DMR) to ICIS-NPDES,
supported by use of the National Environmental Information
Exchange Network (Exchange Network), by all of their NPDES
permitted facilities.
d. Establish that reporting NPDES data using the Exchange
Network (i.e., operations and maintenance) is an eligible
activity for funding under categorical program grants.
e. Based on the information above, States may want to ask your
programs of any additional details about the states plans in
using ICIS-NPDES and the National NetDMR or other e-DMR
tool they might like to include.
f. States using PCS should identify plans, with milestones, for
migrating to ICIS-NPDES and identify any barriers.
g. States should identify plans for using the National NetDMR or
other e-DMR tool.
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b. FY2012 REGIONAL PRIORITIES AND PPA AREAS OF EMPHASIS
Each of these areas of emphasis should be considered during negotiations for the
PPA for FY 2012. It is recognized that there are certain functionslike monitoring,
permitting, inspecting, technical assistance, enforcement, etc.that form the core of
our work. They are the underpinnings of all we do. These special emphasis areas
represent either an outgrowth of our core work, or a focusing of attention on a
particular segment of these core programs. It is because of our ability to perform our
core activities that we have the opportunity to select certain areas for emphasis in
the upcoming year. The following list includes the primary areas of emphasis
including: Regional Priorities and Goals, Environmental Justice (EJ), Inspection
Projections, Compliance Assistance and Facility Watch List.
A. Regional Priorities
In Region 8 there are five overarching strategic goals and several cross-
cutting fundamental strategies that support the Agency's Strategic Plan. This
will assist Region 8 in accomplishing our mission of protecting human health
and safeguarding the environment. Region 8 will work in partnership with
the States and our Tribal Partners to accomplish our goals. The list below
contains Region 8's goals and strategies:
> Taking Action on Climate Change
> Improving Air Quality
> Assuring the Safety of Chemicals
> Cleaning up Our Communities
> Protecting America's Waters
> Expanding the Conversation on Environmentalism and
Working for Environmental Justice
> Building Strong State and Tribal Partnerships
> Agriculture
> Energy
> All Hazards Response
> Technological Innovation
B. Environmental Justice
Environmental Justice is the fair treatment and meaningful involvement of all
people regardless of race, color, national origin, or income with respect to the
development, implementation and enforcement of environmental laws,
regulations, and policies. Fair treatment means that no group of people
including a racial, ethnic, or socioeconomic group, should bear a
disproportionate share of negative environmental consequences resulting
from industrial, municipal, and commercial operations or the execution of
Federal, State, Local and Tribal programs and policies.
States should incorporate environmental justice into their programs, and
document their commitments in the Agreement. There are five general areas
where environmental justice commitments can be made, including
development of environmental justice information: integration of
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environmental justice in ongoing programs; training of staff in environmental
justice principles; full and appropriate involvement of the communities in
environmental decisions and development and application of measures of
success.
Suggested PPA Language:
The State will advance Environmental Justice goals in the
following activities.
> Identify locations of environmental hazards in low income and
minority communities
> Consider disproportionate impacts when permitting major
facilities in low income and minority communities
> Identify and address disproportionate impacts when
conducting enforcement activities in low income and minority
communities
> Seek remedies through enforcement actions which directly
benefit disproportionately impacted low income and minority
communities
> Determine whether any on-going or proposed State activities,
contribute to or cause adverse impacts on low income or
minority populations
> Assist low income and minority communitie4s in developing an
understanding of environmental issues through meetings,
workshops and other appropriate forums
> Communicate with potential environmental justice
communities to assure such communities that environmental
justice concerns are being addressed in and through their
actions
> Ensure that opportunity for community input from low income
and minority populations is considered and obtained early in
the State's processes
> Consider the adoption of an Environmental Justice Policy and
the creation of a review entity, such as an advisory board, to
monitor and address environmental justice issues
> Create evaluation measures to facilitate an assessment of the
effectiveness of environmental justice activities
EPA will provide the state access to environmental justice
information tools, provide information to the State on
environmental justice grants, including Community Action fora
Renewed Environment (CARE), and provide Environmental
Justice training for State staff and managers.
The State and EPA will meet regularly to discuss environmental
justice issues of mutual concern.
C. Inspection Projections
Regions are asked to provide projections of program activity, for regional and
state inspections and for addressing drinking water significant noncompliance
(SNC). The inspection targets for CAA, CWA and RCRA and SNC rates are
tracked in the Annual Commitment System (ACS). For FY 2012 the State
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and Region will hold discussions on projections of program activity target
levels. Activities should be discussed concerning both state and regional
coverage of work, and then recorded in the Agreement. These figures will
also be entered into the ACS for fiscal year tracking.
Suggested PPA Language:
"The State provides target projections for state inspections for each media program
by the end of September of each year."
D. Compliance Assistance
In FY 2012 Compliance Assistance (CA) will continue to be a focus area for
OECA and Region 8. To maximize the effectiveness and results of the
National CA Program, Region 8 asks its state partners to also make a
commitment to using CA as a viable compliance assurance tool. Specifically,
Region 8 would like its states to include language in their PPA Agreements
within each program section as indicated in the following Suggested PPA
Language.
In addition to including the suggested PPA language placed in each PPA
program section, Region 8 asks its states to comply with the following
commitments:
Build and maintain a strong CA core program infrastructure to
encourage effective communication networks. This would include the
identification of one state contact that would represent the state on all
CA issues and efforts. This primary contact person would interface
regularly with the Region 8 CA Program to ensure effective
communication between the state and federal levels.
Identify opportunities for collaboration with Region 8 in terms of CA
projects. This approach maximizes limited resources within both
offices and provides a great learning opportunity for both parties.
Suggested PPA Language:
"This program will include strategic planning as part of its yearly program
planning process, for up front consideration and appropriate use of compliance
assistance in addressing environmental problems (either single media or multi-
media)".
E. Facility Watch List
As OECA has asked the Region's to place a high priority on addressing
enforcement "watch lists" which includes unaddressed Significant Non-
Compliers. The Region will ask the states to commit to: 1) review watch lists,
2) discuss unaddressed facilities with EPA, and 3) coordinate with the Region
on a plan to address them (which may include work-sharing)."
C. OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE (OECA)
PROGRAM PRIORITIES, ENFORCEMENT INITIATIVES, (2011-2013), CROSS
CUTTING STRATEGIES (FY-2011 -FY-2015) AND SIGNIFICANT CHANGES
FROM FY-2011
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A. Program Priorities
OECA's work aligns with and implements the Administrator's priorities in the
following ways:
1. Taking Action on Climate Change: Enforcement supports the
Agency's climate strategy by recognizing reductions of global warming
pollution in settlements of enforcement actions. OECA will be working
to support the integrity of the monitoring and reporting system for
global warming pollution by assuring compliance with the greenhouse
gases reporting rule.
2. Improving Air Quality: Enforcement helps improve air quality in
communities by targeting large pollution sources, especially in the
utility, refinery, cement and glass industries, and taking aggressive
action to bring them into compliance and to install controls that will
benefit communities and improve emission monitoring. OECA is
working closely with the Office of Air and Radiation to reduce toxic air
pollution, through protective enforcement, permitting and standards,
especially in communities that are disproportionately affected by
pollution now. OECA will continue to work with States and Tribes to
improve monitoring of compliance with air pollution standards and
make sure that action is taken against serious violations that affect
community air quality.
3. Assuring the Safety of Chemicals: As the Agency steps up its review
of chemical safety and pushes for reform, OECA will work closely with
OCSPP to achieve its goals. The enforcement program will take
action when we find violations of standards for high-concern
chemicals.
4. Cleaning Up Our Communities: Enforcement ensures that parties
responsible for contamination step up to their cleanup responsibilities.
By ensuring that the polluter pays whenever possible, OECA's efforts
result in more cleanups, which protect more communities from
exposure and returns properties to productive use. OECA will also
use enforcement to spur clean up at RCRA corrective action sites
where the clean up progress is stalled.
5. Protecting America's Waters: OECA is revamping the water
enforcement program to focus on the problems that are the biggest
threat to the nation's waters. At the same time, OECA will increase
oversight of the States and work to define the shared accountability of
EPA, States and Tribes for clean water. OECA will improve
transparency, to enlist the public in holding sources and government
accountable.
6. Expanding the Conversation on Environmentalism and Working for
Environmental Justice: In all the enforcement work OECA does, as
described above, OECA can help protect communities by targeting
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enforcement in areas where we find serious noncompliance and
where communities face multiple pollution threats. OECA works with
other federal agencies to make sure environmental justice
considerations are included in their decision making process as they
prepare environmental analyses (environmental impact statements or
environmental assessments) under NEPA. OECA also will make
more available and understandable information on facility compliance
and government response, so that people have the information they
need to take action to improve their own communities.
7. Building Strong State and Tribal Partnerships: EPA shares
accountability with States and Tribes for protecting the environment
and public health. With the current economic challenges, it is
important that EPA and its partners work efficiently and effectively to
do the most we can with the resources we have. At the same time,
OECA will strengthen oversight of States that implement federal
environmental programs, and support States that take strong
enforcement action to protect their citizens by making sure that we
hold all States to a comparable standard.
B. OECA's Enforcement goals for FY2012 are to:
Aggressively go after pollution problems that make a difference in communities. Use
vigorous civil and criminal enforcement that targets the most serious water, air and
chemical hazards; and advance environmental justice by protecting vulnerable
communities.
1 Clean water
Clean water act action plan: revamp enforcement and work with
permitting to focus on the biggest pollution problems, including
Get raw sewage out of the water
Cut pollution from animal waste
Reduce polluted storm water runoff
Assure clean drinking water for all communities, including in
Indian country
Clean up great waters that matter to communities, e.g,
Chesapeake Bay
2 Clean air
Cut toxic air pollution in communities
Reduce air pollution from largest sources, including coal fired
power plants, cement, acid and glass sectors
3 Climate and clean energy
Assure compliance with greenhouse gas reporting rule
Encourage greenhouse gas emission reductions through
settlements
Target energy sector compliance with air, water and waste rules
4 Protect people from exposure to hazardous chemicals
Prevent releases of hazardous chemicals that threaten public
health or the environment
Press for clean up of hazardous sites in communities: polluter
pays
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Reform chemical management enforcement and reduce exposure
to pesticides focus on specific areas aimed to help achieve clean
water, clean air, and climate and clean energy, and to protect
people from exposure to hazardous chemicals.
Reset our relationship with States: make sure we are delivering on our joint
commitment to a clean and healthy environment.
1. Shared accountability
a. Make joint progress with States and Tribes toward clean air
and water goals, protection from exposure to hazardous
chemicals
b. Work toward shared focus on protecting vulnerable
communities
2. Strengthened oversight
a. Assure strong and effective State enforcement of federal
environmental laws
b. Press for consistent enforcement across States and Regions:
fairness and level playing field
3. Establish new model for shared accountability and strengthened
oversight, starting with water
a. Build focus on highest priority problems into grants,
enforcement and permitting agreements
b. Define clear expectations for state performance
c. Take federal action where not meeting minimum expectations
Improve transparency
Make meaningful facility compliance information available and accessible
using 21st century technologies
Hold government accountable through public information on state and
federal performance
Promote better federal environmental decisions and public engagement
through NEPA
C. Development of Enforcement Initiatives
To help implement these enforcement goals, OECA selects a limited number of
National Enforcement Initiatives based upon significant environmental risks and
noncompliance patterns. In FY 2010, EPA re-examined the existing initiatives to
look for opportunities to clarify goals and measures, more accurately identify
universes of sources, and, where necessary, to change the focus of an Initiative.
In addition, EPA considered candidates for new National Enforcement Initiatives.
After consulting with EPA programs and Regions, States, Tribes, and the public,
OECA adopted the following National Enforcement Initiatives for 2012 through
2013; more information on each is found in the media sections of the OECA NPM
guidance:
1. Keeping raw sewage and contaminated stormwater runoff out of our
waters
2. Cutting animal waste to protect surface and ground waters
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3. Reducing widespread air pollution from the largest sources, especially
the coal-fired utility, cement, glass, and acid sectors
4. Cutting toxic air pollution that affects communities' health
5. Assuring energy extraction sector compliance with environmental laws
6. Reducing pollution from mineral processing operations
D. Cross Cutting Strategies in the FY2011-2015 Strategic Plan
1. Expanding the Conversation on Environmentalism
a. Data regarding state assessments, priorities and performance
under the Clean Water Act (CWA) should be made public,
where possible, on a regular basis in a manner easily
understood and used by the public
b. Compliance data should distinguish State information from
Indian country information
c. Information should be made available to communities,
including Native American and Alaskan Natives, who lack
access to the internet
d. Criminal Enforcement program will continue to develop its use
of new outreach methods such as Facebook, Twitter and
mobile applications to encourage the public's reporting of
potential violations and to provide leads through the fugitives
website www.epa.gov/fugitives/
2. Strengthening State, Tribal and International Partnerships
a. Regions will continue to implement the CWA Action Plan in
FY2012 by collaborating with states to address NPDES
permitting, compliance monitoring, and enforcement activities,
including work-sharing
b. A majority of program narratives in the FY2012 guidance
contain specific activities regarding state relationships
c. Regions should consult as appropriate, with potentially
impacted tribal governments when conducting inspections and
addressing noncompliance at tribal and non-tribal facilities in
Indian country
3. Working for Environmental Justice (EJ) and Children's Health
a. Regions are directed to use the Agency's environmental
justice tools and methodologies to focus enforcement and
compliance efforts in communities overburdened by exposure
to environmental risks, including minority and low-income
communities, as well as those with greater concentrations of
sensitive populations
b. Specific OECA (EJ) performance expectations, which include
children's health as appropriate, are discussed in Section II of
the OECA FY-2012 NPM Guidance
E. Significant Changes from FY2010
The Office of Enforcement and Compliance Assurance's FY 2012 guidance
continues to focus on the Administrator's goals, and on aligning enforcement and
compliance priorities with those of the other EPA national managers. As in the FY
2011, the FY 2012 guidance is organized to describe the specific expectations for
Regions that implement the Administrator's priorities and explains how the
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enforcement program supports the priorities of other EPA national programs. There
are some notable changes in specific programs contained within this guidance and
can be summarized as follows:
1. Clean Water Action Plan: The FY2012 guidance contains more specific
instructions for the regions and states on how to implement the Clean Water
Action Plan such as replacing existing paper reporting with electronic
reporting, creating a new compliance paradigm, retooling key NPDES
permitting and enforcement activities, and conducting comprehensive and
coordinated permitting, compliance, and enforcement programs.
2. Wetlands Program: The FY2012 guidance sets expectations for the regions
to participate in a Section 404 Enforcement Strategy pilot program to improve
coordination and communication between EPA and the Corps of Engineers to
improve management of the wetlands protection program.
3. Oil Spills: In light of the events of the British Petroleum oil spill the FY2012
guidance has been expanded to provide more detailed instructions on the
compliance and enforcement activities of an effective oil spill program.
4. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Program:
Each year regions are asked to place special emphasis on key focus areas
within the FIFRA program. In FY2012, an optional focus area has been
included to provide flexibility to the regions on where to focus their efforts.
This flexibility allows for more opportunities to support the Office of Chemical
Safety and Pollution Prevention's program priorities.
d. PROGRAM OVERSIGHT
State RCRA, NPDES, Air, and PWSS enforcement program performance will be
evaluated as described in the attached draft document entitled, Regional Plan for
Region 8's Implementation of the State Review Framework (SRF), Uniform
Enforcement Oversight System (UEOS) and Other Oversight Activities for the
CWA NPDES, CAA Stationary Sources, RCRA Subtitle C, and Public Water
System Supervision (PWSS) Enforcement Programs through FY 2012 and as
described in the state-specific State Oversight Plan which will be forwarded to each
state environmental director in draft for comment by April 30 of each year and as
final no later than September 30 of each year. Oversight activities planned for FY
2012 are based on program performance as determined through the OECA/ECOS
State Review Framework (SRF) and, for PWSS, Uniform Enforcement Oversight
System (UEOS) evaluations as well as in the FY2010 end-of-year reports.
National data that will be used to support the SRF reviews are available to the
regions and states through OTIS management reports and states are encouraged to
periodically look at the data, ensure its accuracy, and use it in managing their
programs. The OTIS management reports and other information regarding the SRF
are available at: http://www.epa.gov/idea/otis/stateframework.html.
Suggested PPA Language
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"State RCRA, NPDES, Air, and PWSS enforcement program performance
will be evaluated as described in the draft Regional Plan for Region 8's
Implementation of the State Review Framework (SRF), Uniform
Enforcement Oversight System (UEOS) and Other Oversight Activities
for the CWA NPDES, CAA Stationary Sources, RCRA Subtitle C, and
Public Water System Supervision (PWSS) Enforcement Programs
through FY2012(which was included with the FY2012 PPA Guidance to
States) and as described in the state-specific State Oversight Plan."
e. PROGRAM SPECIFIC GUIDANCE
A. CAA- National Enforcement Initiatives
a. Air Toxics in Communities
a. Maximum Achievable Control Technologies (MACT)
a. The MACT program has been identified by OECA
as a national priority. During the FY 2011 -2013
period, the national enforcement initiative will focus
on excess emissions caused by facilities failure to
comply with LDAR, flaring and excess emissions
during start-up, shutdown and malfunctions.
Region 8 will continue with its LDAR efforts at
MACT HH facilities and investigating flaring at
refineries, and oil and gas facilities.
Suggested PPA Language
"During the FY2011-2013 period, EPA and the State will collaborate on
investigating and inspecting facilities as they relate to LDAR under MACT
HH and flaring at refineries and oil and gas facilities. Also, facilities with
excess emissions during start-up, shutdown and malfunctions will be
targeted for investigations and inspections."
b. States will provide information to EPA adequate to
support a complete and up-to-date universe of
MACT facilities in Region 8. States will annually
submit a written and electronic report to EPA by
November of the fiscal year for which this guidance
is forwarded, to include the MACT sources in the
respective States (including the facility's name,
AFS number, MACT Subpart and source size
classification).
c. EPA Region 8 will also conduct lead inspections
targeting facilities for those MACTs which the state
has not received delegation.
d. EPA Region 8 will continue to provide guidance
and assistance in rule implementation, compliance
determinations, and other case by case issues
where EPA may need to make a final decision.
Suggested PPA Language
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"During FY2011, the State will provide information to EPA adequate to
support a complete and up-to-date universe of MACT facilities. The State
will annually submit a written and electronic report to EPA by November
of the fiscal year for which this guidance is forwarded to include, the
sources within the MACT categories for which delegation has been
accepted (including the facility's name, AFS number, MACT Subpart and
source size classification)."
b. New Source Review/Prevention of Significant
Deterioration (NSR/PSD)
a. During FY2011-2013, OECA has determined that
EPA will continue its PSD/NSR enforcement efforts
against refineries, coal-fired power plants, cement
plants, sulfuric and acid plants, and glass
manufacturing facilities. Region 8 will continue to
develop and settle regional cases involving
PSD/NSR compliance issues at coal-fired power
plants, refineries, cement plants, sulfuric/nitric acid
plants, and glass manufacturing facilities.
Suggested PPA Language:
"EPA will continue to investigate facilities for potential violations of
PSD/NSR requirements focusing on Coal Fired Power Plants,
Refineries, Cement Plants, Glass Manufacturers, Sulfuric/Nitric Acid
Plants and Oil and Natural Gas Production facilities."
b. Energy Extraction
a. OECA has selected Energy Extraction as a new sector for
FY2011-2013. Region 8 will continue to focus on oil & natural
gas facilities as it relates to PSD, MACT Subpart HH and
Subpart 7.7.72. and other areas as identified in the energy
extraction strategy that will be finalized later this summer.
Suggested PPA Language:
"EPA will continue to investigate oil and natural gas facilities for potential
violations of PSD, MACT Subpart HH and Subpart ZZZZ and other areas
of potential concern. EPA investigations will be primarily focused on tribal
lands but may include investigations of companies operating across
tribal/state jurisdiction."
c. CAA - Core
1. Additional state specific language may be discussed during the
negotiation of the Agreement in accordance with the results of the
enforcement programs State Review Framework.
2. The Annual Commitment System (ACS) for FY2012 requires that
draft targets (inspection numbers) be entered into the system by
July 1st, 2011 and are finalized September 30th, 2011. States will
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provide EPA with its inspection numbers so that EPA can submit
the data into the system by the required timelines.
3. The States should continue to implement the CMS, National Stack
Testing Guidance, HPV Policy, and the Area Source
Implementation Guidance.
B. CWA-NPDES
a. Clean Water Act Action Plan
OECA is currently working with EPA regions, states and the
Office of Water to implement the CWA Action Plan (the Action
Plan) issued in October 2009. The Action Plan's three key
elements are: 1) to focus our NPDES enforcement efforts on
pollution sources that pose the greatest threats to water quality;
2) to strengthen oversight of state permitting and enforcement
programs; and 3) to improve the accessibility and quality of
information we provide to the public. These elements are
consistent with the Assistant Administrator's goals for the
compliance and enforcement program, which includes
aggressively going after pollution problems that make a
difference in communities, resetting our relationships with States
and making important information available to the public. In
support of the Action Plan, EPA and States will:
o Conduct planning meetings between EPA and State
NPDES compliance and enforcement, permitting and
water quality standards personnel to identify water
quality issues of greatest concern for each state, and
develop collaborative annual work plans to leverage both
State and EPA resources to address these issues. Plans
for FY2012 will be developed by September 15, 2012.
o Conduct quarterly meetings between EPA and each
state to discuss progress towards meeting annual
permitting and enforcement commitments.
Suggested PPA Language
"The State and EPA will work together to implement the Clean
Water Act Action- Plan. The State and EPA will conduct planning
meetings including NPDES compliance and enforcement,
permitting and water quality standard personnel to identify water
quality issues of greatest concern for each state, and develop
collaborative annual work plans to leverage both State and EPA
resources to address these issues. A collaborative work plan will
be developed prior to September 15, 2011 for FY2012. The State
and EPA will conduct quarterly meetings to discuss progress
towards meeting annual permitting and enforcement
commitments."
b. NPDES National and Regional Enforcement Initiatives
EPA will perform inspections in regional and national
enforcement initiatives according to national guidance and the
national 2011-2013 Performance Based Strategies and the
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collaborative annual work plans. The enforcement initiatives
include: Municipal Wet Weather Infrastructure, which includes
Sanitary Sewer Overflows (SSOs), Combined Sewer Overflows
(CSOs) and Municipal Separate Storm Sewer Systems (MS4s);
Concentrated Animal Feeding Operations (CAFOs); and Energy
Extraction. EPA will conduct inspection follow up and
enforcement for those facilities it inspects.
States are encouraged to pilot the Wet Weather SNC Policy in
FY12.
Suggested PPA Language
"EPA will perform inspections in regional and national
enforcement initiatives according to national and regional
guidance and the national 2011-2013 Performance Based
Strategies and the collaborative annual work plans. The
enforcement initiatives include: Municipal Wet Weather
Infrastructure; Concentrated Animal Feeding Operations (CAFOs);
and Energy Extraction. EPA will conduct inspection follow up and
enforcement for those facilities it inspects. "
"States are encouraged to pilot the Wet Weather SNC Policy in
FY12. "
Municipal Wet Weather Infrastructure
a. Sanitary Sewer Overflows (SSO)
Each state should continue to implement its draft SSO
response plans. SSOs must be entered into PCS/ICIS-
NPDES as single event violations in accordance with the PCS
Policy Statement and its addendums.
States should commit to provide to EPA by October 15, 2011
the following information: a) an updated SSO inventory; b) the
number of NPDES inspections targeted to identify SSOs; c)
the number and percent of SSO inspections in priority
watersheds including the name of the priority watershed; d)
the number and type of informal and formal enforcement
actions taken in response to SSOs; e) the percent of
enforcement actions in priority watersheds for SSO; and f) a
list of SSOs addressed. Copies of all SSO inspections and
enforcement actions should be submitted to EPA.
EPA and states continue to investigate municipal systems to
determine whether the systems have an appropriate operation
and maintenance system and adequate capacity to handle
current and projected flows. Based on these investigations,
EPA has set goals for addressing SSOs for large municipal
systems (total treatment capacity of > 100 MGD) and medium
municipal systems (total treatment capacity of > 10 MGD, <
100 MGD) and their associated satellite systems. A facility is
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considered "addressed" when one of the following conditions
is met:
a. The facility is under a final federal administrative
order (AO) or entered federal civil judicial consent
decree that includes an enforceable schedule with
milestones to implement any necessary remedial
measures, and ensure that an adequate operation
and maintenance program is in place; or
b. The facility is named in a federal civil judicial
complaint that has been filed; or
c. The facility is subject to an enforceable state
administrative or judicial order that meets federal
requirements for compliance expeditiously and
includes appropriate penalties; or
d. The facility received a federal investigation which
documents a de minimus spill rate and that
adequate capacity, operation and maintenance
procedures are in place to maintain the de minimus
spill rate.
We will be discussing state-specific and EPA-specific
commitments for meeting the goals of investigating and
addressing medium municipal systems and their
associated satellites in FY12. The level of commitment we
will be asking for will be based on the number of medium
systems in the state as well as the progress the state and
EPA have already made towards addressing these
systems. EPA will conduct a portion of the investigation
and enforcement follow up for systems in the states.
Suggested PPA Language
Enter SSOs into PCS/ICIS-NPDES as single event violations in
accordance with the PCS Policy Statement and its addendums.
The State will provide to EPA by October 15, 2011 a report
including the following information: a) an updated SSO inventory;
b) the number ofNPDES inspections targeted to identify SSOs; c)
the number and percent of SSO inspections in priority watersheds
including the name of the priority watershed; d) the number and
type of informal and formal enforcement actions taken in response
to SSOs; e) the percent of enforcement actions in priority
watersheds for SSO; and f) a list of SSOs addressed. Copies of
all SSO inspections and enforcement actions should be submitted
to EPA.
The State and EPA will conduct an investigation of the current
operation and maintenance, capacity and future capacity, based
on projected increase of flows, for the following systems:
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(systems to be determined by State and EPA based on the
number of medium systems in the State as well as the progress
the State and EPA have already made towards addressing these
systems. The systems will be identified as receiving either an EPA
or State investigation.) The investigation may consist of a review
of information provided by the municipalities and satellite systems,
inspections of the collection systems or any other means that
accurately characterizes the system.
For those systems that the State conducts the investigation, the
State will provide EPA the operation and maintenance and
capacity analysis for the systems identified by (date agreed
upon by EPA and State). If the State determines that a facility
does not have adequate operation/maintenance procedures,
capacity or the mechanisms to ensure that the additional capacity
is provided commensurate with increase in flows, the State and
system will enter into an administrative or judicial action which
includes an enforceable schedule and appropriate penalty. For
those systems the State determines have a de minimus spill rate
and are properly designed, operated and maintained, EPA will
review the State analysis and will conduct any necessary follow up
(inspections, information requests, etc.) to determine if EPA can
support the State's determination. For those systems which EPA
conducts the investigation and determines that an enforceable
schedule is warranted, EPA will take the enforcement action, or
consider joint EPA/State enforcement to address the issues. In
addition, other smaller municipal collection systems causing
identifiable and significant public health and/or water quality
impacts shall be similarly addressed."
2. Storm Water
States should indicate in the PPA the number of
inspections they intend to perform (this number should
indicate the number of Phase I and Phase II MS4
audits and inspections; the number of Phase I and
Phase II storm water construction inspections; and the
number of storm water industrial non-construction
inspections). Storm water inspections should be
incorporated in the annual NPDES inspection plan
which should identify the names of the targeted
industrial facilities, where known, the geographic area
targeted for construction inspections, and sector areas
targeted. Priority should be given to conducting storm
water inspections at non-filers, where there is water
quality degradation, and in response to citizen
complaints. States should conduct audits of Phase I
MS4s every 5 years, and inspect them as needed
based upon permit compliance. The current goal of the
initiative is to address all Phase I MS4s by FY16.
States should implement their Phase II audit and
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inspection plan to determine compliance at all Phase II
MS4s within the next three years. Commitments for
conducting inspections of Phase I and II storm water
construction sites and industrial sites should be based
on the collaborative annual work plan and Compliance
Monitoring Strategy (CMS). Storm water inspections
should be entered in PCS/ICIS-NPDES or reported to
EPA manually by April 30 and October 31 of each year
if the state chooses not to enter the inspection into
PCS or ICIS-NPDES. Manual reports should contain
the same information that would be provided in
PCS/ICIS-NPDES. Copies of all storm water inspection
reports and enforcement actions should be provided to
EPA.
States shall provide EPA with a copy of their current
storm water permit tracking system (or a list of all new
and inactivated storm water permits) semiannually by
April 30 of and October 31 of each year. Quarterly,
States shall provide EPA with a current number of
industrial and Phase I and Phase II construction storm
water permits (October 31, January 31, April 30 and
July 31).
States should agree to update the State Enforcement
Response Guide (ERG) to include storm water within
six months of EPA's final storm water ERG
States that have joined EPA in a national enforcement
case will agree to inspect an agreed upon subset of
new sites after the consent degree is final. These
inspections will be memorialized in the state's
inspection plan.
Suggested PPA Language
"The State will perform Phase IMS4 audits, Phase I
MS4 inspections, Phase IIMS4 audits, Phase IIMS4
inspections, Phase I construction inspections, Phase II
storm water construction inspections, and storm water
industrial non-construction inspections in FY12. The number of
storm water inspections the State conducts will be incorporated in
the annual NPDES inspection plan which will identify the names of
the targeted industrial facilities, where known, the geographic area
targeted for construction inspections, and sector areas targeted.
Priority will be given to conducting storm water inspections at non-
filers, where there is water quality degradation, and in response to
citizen complaints."
"Storm water inspections will be entered in PCS/ICIS-NPDES or
reported to EPA manually by April 30 and October 31 of each year
if the State chooses not to enter the inspection into PCS or ICIS-
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NPDES. Manual reports should contain the same information
that would be provided in PCS/ICIS-NPDES. Copies of all storm
water inspection reports and enforcement actions should be
provided to EPA."
"The State will provide EPA with a copy of its current storm water
permit tracking system (or a list of all new and inactivated storm
water permits) semiannually by April 30 and October 31.
Quarterly, the State will provide EPA a current number of
industrial and Phase I and Phase II construction storm water
permits (October 31, January 31, April 30, and July 31)."
"The State will update the State Enforcement Response Guide
(ERG) to include storm water within six months of EPA's final
storm water ERG."
"If the State has/will join EPA in a national enforcement case, it
will agree to inspect an agreed upon subset of new sites after the
consent degree is final. The agreed upon subset will be
memorialized in the State's Inspection Plan.
3. Concentrated Animal Feeding Operations (CAFO)
States should continue to implement and update as necessary,
based on the 2008 Final CAFO rule and the collaborative annual
work plan, state-specific CAFO compliance and enforcement
strategies and conduct compliance assistance and enforcement
as appropriate.
States should submit by December 31, a CAFO inventory and
inspection status report explaining the progress made towards
inspecting CAFOs and its progress toward inventory development.
Region 8 will share with States information gathered through
national CAFO inventory efforts (i.e. satellite imagery, flyovers,
inspections, and database reviews). Each state should agree to
inspect permitted CAFOs at least once during the life of its permit.
States should also commit to inspecting all unpermitted large
CAFOs at least once within the next 5 years to determine whether
the facility discharges, and all medium AFOs once to determine if
it is a medium CAFO and requires an NPDES permit. Formal
enforcement is expected for any large or medium CAFO
determined to have discharged. The state should propose a
number of CAFO inspections for the PPA to meet this
commitment.
States are encouraged to utilize PCS/ICIS-NPDES for their
inventories. However, if States use tracking methods or systems
other than PCS/ICIS-NPDES to maintain such an inventory,
States will need to coordinate with the Region to ensure
accessibility (such as quarterly hard copy reports) of the
information, including permit, inspection, and complaint and
enforcement data. States shall submit copies of all CAFO
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inspection reports and enforcement actions to the Region 8
NPDES Enforcement Unit. Inspections and enforcement actions at
CAFOs with NPDES permits shall be entered into PCS/ICIS-
NPDES. Nutrient Management Plans shall also be tracked in
PCS/ICIS-NPDES as a compliance schedule item as required by
the PCS Policy Statement and its addendums.
Region 8 will conduct up to four joint/oversight CAFO inspections
in each state (in addition to other oversight inspections).
Each state shall include in its end-of-year report the number of
compliance assistance workshops, training sessions, and/or
presentations given for AFO/CAFO operators and/or Ag
organizations.
Suggested PPA Language
"The State agrees to implement and update as necessary, based on the
2008 Final CAFO Rule and collaborative annual work plan, state-specific
CAFO compliance and enforcement strategies and conduct compliance
assistance and enforcement as appropriate. The State will include in its
end-of-year report the number of compliance assistance workshops,
training sessions, and/or presentations given for AFO/CAFO operators
and/or Ag organizations. The State will submit by December 31, a CAFO
inventory and inspection status report explaining the progress made
towards inspecting CAFOs, and its progress toward inventory
development. Region 8 agrees to share with the State any information
gathered through national CAFO inventory efforts (i.e. satellite imagery,
flyovers, inspections, and database reviews). The State will inspect
permitted CAFOs at least once during the life of its permit and all
unpermitted large CAFOs at least once within the next 5 years to
determine whether the facility discharges, and all medium AFOs at least
once to determine if it is a medium CAFO and requires an NPDES permit.
During FY10, the State commits to inspecting permitted CAFOs,
unpermitted large CAFOs, and medium AFOs to achieve this goal.
The State will consider using PCS/ICIS-NPDES for development of its
CAFO inventory. Inspections and enforcement actions at permitted
CAFOs will be entered into PCS/ICIS-NPDES by the State, and Nutrient
Management Plans will be tracked in PCS/ICIS-NPDES as a compliance
schedule item as required by the PCS Policy Statement and its
addendums. The State will provide quarterly reports to EPA (submitted
10/31, 1/31, 4/30, and 7/31) of any inventory that is maintained outside of
PC/ICIS-NPDES for the tracking of CAFO permit, inspection, complaint
and enforcement data. This tracking system should include information
on CAFOs that have been determined to discharge. The State agrees to
submitting copies of all CAFO inspection reports and enforcement actions
to the Region 8 NPDES Enforcement Unit. The State agrees to EPA
Region 8 conducting up to four CAFO joint/oversight inspections during
FY12, in addition to other oversight inspections."
4. Energy Extraction Sector
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OECA has selected Energy Extraction as a new sector for
FY2011-2013. This strategy is currently under development.
Once finalized, EPA and states will discuss specific actions for
inclusion in the FY12 PPA.
c. Improve Transparency
a. States must ensure that the minimum data requirements
identified in the PCS Policy Statement and its addendums are
tracked in PCS/ICIS-NPDES. States are encouraged to
expand the use of PCS/ICIS-NPDES to track all NPDES
compliance and enforcement activities.
b. States which are not using PCS/ICIS-NPDES to track all of its
inspection and enforcement activities must report out Mid-Year
(April 30, 2012) and in the End-of-Year Report its inspection
activities manually. Information that must be reported
includes;
Number of majors inspected
Number of minors inspected
Number of storm water inspections (specify # of
construction phase I and phase II inspections #
of industrial inspections and MS4 phase I and II
conducted)
iv. Number of CAFO inspections
v. Number of Biosolids inspections (if applicable)
vi. Number of CSO and/or SSO inspections
vii. Number of pretreatment inspections including
industrial users
c. For states that are using PCS/ICIS-NPDES to track all
activities, EPA will pull inspection and enforcement information
from the database at midyear and end-of-year. States must
enter all types of inspections in PCS/ICIS-NPDES by April 30
for midyear reporting and October 31, for End-Of-Year
reporting.
d. States are encouraged to us the Interim Wet Weather
Significant Noncompliance Policy for violations associated with
CSOs, SSOs, CAFOs, and storm water.
e. Non-major Facilities Non-compliance Report
States should include a commitment to submit the
annual non-major facilities noncompliance report for
the period of 1/01/2011 -12/31/2011 in accordance
with 40 CFR ง123.45 (c) by April 30, 2012. States may
opt to maintain PCS/ICIS-NPDES and have this
information pulled from PCS/ICIS-NPDES in lieu of
annual reporting. States should specify in the PPA
which option they are choosing for this report.
d. Federal Facilities
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a. During FY11, EPA Region 8 may perform inspections at all
Federal Facility construction sites that have been awarded
contract dollars for site construction.
e. State EPA NPDES Inspections
a. States should submit a draft inspection plan for FY12 (October
1, 2012 -September 30, 2013) by August 1, 2012. EPA will
provide comments by August 15, 2012. States should submit a
final inspection plan no later than September 1, 2012. When
developing the annual State/EPA NPDES inspection plan,
States should address national, regional, and State priority
areas and sectors which are applicable to the state.
b. States must maintain an effective inspection program in each
of the water program areas. States should continue
implementing the NPDES Compliance and Monitoring Strategy
in FY12. The inspection plan should clearly outline how it is
complying with the provisions of the strategy, including a
detailed description of how its inspection commitments for both
the traditional NPDES core program and national enforcement
initiatives will be allocated in FY12. Minimum numbers of
inspections for the core programs and priority areas are
identified in the Compliance Monitoring Strategy.
c. EPA will conduct up to 6 oversight inspections in each state.
These oversight inspections will be conducted to support
baseline and targeted oversight, as well as the State Review
Framework (SRF) review. The oversight inspections may be
conducted by either: 1) accompanying state inspectors during
an inspection or 2) by EPA conducting an independent
inspection at the same facility at a later date to verify the state
findings. EPA may also conduct additional oversight
inspections in the national and regional enforcement initiative
areas. EPA will target facilities for oversight inspections with
states.
f. States should agree to periodically submit to EPA copies of:
Final settlement agreements (or state equivalent to that
type of document),
The State's penalty calculations including justifications
for adjustments and economic benefit calculations for
state enforcement actions concluded during the fiscal
year
A description of any supplemental environmental
projects included in state enforcement actions
concluded during the fiscal year.
g. 404/402 Enforcement Actions
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a. In the interest of maximizing resources, states will agree to
EPA being the lead enforcement agency on all 404
enforcement actions that have associated 402 violations,
except where EPA determines combined cases may not be in
the best interest of the litigation.
C. Safe Drinking Water Act (SOWA)
I. Microbial Rules
1. By November 15, 2011, provide to EPA a list of all systems that
are required to filter under the SWTR, but are not yet filtering.
Additionally, report those violations to SDWIS-Fed. For those still
on compliance schedules, provide the schedule from the
enforcement document. If any systems are not under compliance
schedules, for each system provide a rationale and the proposed
state action and time frame for securing an enforceable
compliance schedule.
2. By November 15, 2011, provide to EPA a description of any
additional actions and the time frames for completing
assessments of groundwater under the influence of surface water,
and the systems for which such assessments need to be
completed.
II. New Rules
Region 8 does not foresee any new rules for which states do not
have primacy in FY 2012, which may necessitate federal
enforcement actions. However, if the situation exists in which a
state does not have primary enforcement authority for any rule,
cooperate with EPA in identifying water systems and violations for
which EPA may need to issue enforcement actions.
SDWA Enforcement
From OECA NPM Guidance:
"The ERP directs that if a PWS reaches an ETT score of 11 or
higher before its violations are resolved, that PWS will be
considered a priority system that must either return to compliance
or receive formal enforcement action within six months of having
reached a score of 11. It is OECA's expectation that primacy
agencies will simultaneously be working to reduce their backlog of
systems that have already been at a score of 11 or higher for
more than 6 months. As a longer term goal, primacy agencies are
encouraged to address violations at non-complying PWSs before
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they become priority systems. A quick response to SDWA
violations decreases the risks to public health and allows primacy
agencies more flexibility as they work with PWSs to achieve
sustained compliance. By focusing resources on PWSs in this
way, the ERP helps ensure those PWSs return to compliance in a
timely manner."
1. Annotate the quarterly Enforcement Targeting Tool (ETT) list
created by the Enforcement Response Policy (ERP) by indicating
the State actions planned for each identified priority ETT system,
the projected time frame for such actions, and other relevant
information that helps EPA evaluate candidates for federal
enforcement. Return the annotated list to EPA within 30 days.
2. Address all priority ETT systems (through formal enforcement or
appropriate return to compliance) within 6 months of their being
identified as priorities, with the goal of taking action before
systems reach the priority status.
3. State enforcement escalation policy:
EPA encourages Region 8 states to update their
enforcement escalation policies to ensure that all violations
receive a state response, and that enforcement priorities
are addressed in a timely and appropriate manner.
IV. SDWA Oversight
1. The following commitments will need to be made by the States in
order for EPA to conduct Enforcement Oversight:
a. Cooperate with EPA and provide access to State PWS
files and data for EPA's on-site enforcement review at the
State office and UEOS evaluation
b. Upload all enforcement actions and applicable return to
compliance codes into SDWIS-Fed quarterly.
c. Additional State-specific language will be discussed during
the negotiation of the Agreement, in accordance with
results of the enforcement program's Uniform Enforcement
Oversight System or End of Year Report.
C. Resource Conservation and Recovery Act (RCRA)
a. Mineral Processing and Mining Priority:
1. The Region will continue to work with HQ and the State to define the
anticipated universe for Mineral Processor and Mining priority
inspections.
b. Additional State-specific language will be discussed during the
negotiation of the Agreement in accordance with results of the
enforcement program's State Review Framework.
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c. For facilities with significant non-compliance as defined in the
Agency's Enforcement Response Policy, States will need to enter
SNC status in RCRAINFO and address SNC facilities through
appropriate enforcement follow-up. The Region will review SNC
facilities on a quarterly basis and discuss with the State enforcement
strategies to address longstanding non-compliance. A written report
of efforts to address SNC facilities and return them to compliance will
be prepared.
d. Core Program Requirements
a. Treatment, storage and disposal facilities: Inspect at least
once every two years each operating treatment, storage and
disposal facility, as required under SWDA ง3007(e), i.e., 50%
of TSDF universe annually.
b. Generators (LQGs): Annually inspect at least 20% of the
large quantity generator universe, so that the entire universe is
inspected in five years. The large quantity generator universe
is the total number of generators that reported in the most
recent biennial report.
If inspection coverage is not expected to be provided
for 20% of LQGs on an annual basis, the states must
provide an explanation that should include the following
a. Information on how the RCRA compliance
monitoring resources will be redirected (e.g.,
national priority facilities, state priority
facilities, never-inspected SQGs.
b. How LQGs will otherwise be monitored (e.g.,
file reviews, watch list).
c. For states proposing to redirect resources to
never-inspected SQGs, information that
shows no un-inspected LQGs in RCRAInfo
(not including facilities that notified in the last
five years).
Because inspections at LQGs generally require more
resources than an inspection at an SQG, inspection
tradeoffs - the number of SQGs substituted for LQGs -
should be at a 2:1 or greater ratio. As alternative
approach to this substitution scheme is described in
the 2009 NPM guidance and will be discussed and
evaluated with the State if requested.
Suggested PPA Language
"The State commits to implement and provide to EPA by November 15th, an
inspection plan which meets the requirements of the Core Program with
emphasis on never inspected LQGs, citizen complaints, and national
priorities. Financial responsibility is a component of this inspection
requirement."
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Region and State will project the number of high priority open dumps to be
investigated and/or inspected to determine the appropriateness of
enforcement to address specific incidents of illegal dumping in Indian
country. Regions will commit to investigating 10% of the identified high
priority open dumps using OECA's targeting strategy, developed in FY2010.
For non-BIA schools in Indian country, Region and State will project the
number of on-site compliance assistance visits designed to ensure the
proper and compliant treatment, storage and disposal of hazardous waste.
c. Federal Core Program Requirements
State or Local Government Operated Facilities:
Annually inspect each treatment, storage or disposal
facility operated by states or local governments as
required under SWDA ง3007(d)
Treatment, Storage and Disposal Facilities: Annually
inspect at least 2 TSDs per state.
Generators (LQGs):
a. Annual inspect at least 2 generators per state.
The region may perform the inspections in the
following areas:
1. national priority sectors,
2. to support state referrals,
3. to address illegal recycling,
4. entities with violations in more than one
state,
5. environmentally sensitive environments,
6. areas subject to environmental justice
concerns,
7. and particularly recalcitrant violators.
Suggested PPA Language
"The Region commits to work with the State to identify 2 TSDFs and 6
LQGs which the Region will inspect as lead. The LQGs will be identified
from the national priority sectors, illegal recyclers, entities with violations
in more than one state, environmentally sensitive environment,
unpermitted surface impoundments, coal combustion waste facilities,
areas of environmental justice concerns and particularly recalcitrant
violators. Twenty percent (20%) of these inspections should be in Indian
Country. When the universe of TSDFs and LQGs is very small a lesser
number of Regional lead inspections will be negotiated. The Region
commits to inspect, State or Local government TSDFs as required by
Statute. At least 20% of the LOG universe should be covered by
combined federal and State inspections unless an alternative plan is
approved under the RCRA CMS".
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d. Financial Assurance
OECA has identified financial assurance as a national
priority. This will include the review of
Treatment, storage and disposal ("TSD") as well as
corrective action facility files to ensure that the RCRA
owner/operator has submitted acceptable financial
assurance documentation as required in the respective
permit or enforcement document.
File reviews at the State offices, specifically to identify
operator compliance with State RCRA regulations
which comport to C.F.R. 264 Subpart H. The States
will participate in this review process by making
available their operator files, permits and enforceable
documents to Region 8 staff. Determinations of
operator compliance are on going, and follow-up on
identified concerns will be made by the States and/or
Region 8 using standard compliance or enforcement
tools.
Suggested PPA Language
"The State and Region 8 will work together to move closure/post closure
and corrective action facilities to compliance with financial assurance
requirements through the development of enforcement cases which may
be taken by either the State or EPA. Region 8 will be the lead for entities
with facilities in more than one state. Regions must commit to review at
least four (4) financial test and/or corporate guarantee submissions per
year for compliance with the closure and post-closure regulations.
Regions may instead choose to review other types of financial assurance
instruments for facilities that did not have a financial assurance review
during the national enforcement priority. The reviews should be formal
Financial Records Reviews..
For 100% of the financial test submissions (corrective action facilities)received
each fiscal year with cost estimates over $5 million, determine whether the
submission is in compliance.
DATA: Maintain RCRAInfo database
Regions are to coordinate with State to review at least (2) financial test
and/or corporate guarantee submissions per year in each State. Reviews
should be formal Financial Records Reviews and take place soon after
the submissions are received.
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FY2012
Office of Enforcement and
Compliance Assurance (OECA)
Final
National Program Manager (NPM) Guidance
April 30,2011
Publication Number:
300F1105
FY2012 OECA NPM Guidance Page 1
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Table of Contents
EXECUTIVE SUMMARY 4
A. PROGRAM OFFICE 4
B. INTRODUCTION/CONTEXT 4
C. PROGRAM PRIORITIES 4
E. CROSS CUTTING STRATEGIES IN THE FY2011-2015 STRATEGIC PLAN 8
F. SIGNIFICANT CHANGES FROM FY2011 10
G. CONTACTS 10
SECTION I: OECA GUIDANCE DEVELOPMENT AND FEEDBACK PROCESS 12
SECTION II: SPECIFIC ENVIRONMENTAL JUSTICE PROGRAM PERFORMANCE EXPECTATIONS
12
1. Advance EJ goals through Selection and Implementation of National Enforcement Initiatives 13
2. Advance EJ Goals Through Targeting and Development of Compliance and Enforcement Actions.... 13
3. Enhance Use of Enforcement and Compliance Tools to Advance EJ Goals in Regions' Geographic
Initiatives to Address Overburdened Communities 14
4. Seek Appropriate Remedies in Enforcement Actions to Benefit Vulnerable and Overburdened Communities
and Address EJ Concerns 15
5. Enhance Communication with Affected Communities and the Public Regarding EJ Concerns and the
Distribution and Benefits of Enforcement Actions, As Appropriate 16
SECTION III: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS ENVIRONMENTAL
PROBLEMS FROM AIR POLLUTION 18
A. CLEAN AIR ACT (CAA) 18
1. Implement National Enforcement Initiatives 18
2. Linkwith Top Office of Air andRadiation Priorities 19
3. Aggressively Go After Pollution Problems That Make a Difference in Communities 20
4. Reset Our Relationships with States 22
5. Improve Transparency 23
6. Relevant Policies and Guidances 23
SECTION IV: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS ENVIRONMENTAL
PROBLEMS FROM WATER POLLUTION 25
A. CLEAN WATER ACT (CWA) 25
1. Clean Water Act Action Plan 25
2. High Priority Performance Goal 26
3. Implement National Enforcement Initiatives 27
4. Linkwith Top Office of Water Priorities 29
5. Aggressively Go After Pollution Problems That Make a Difference in Communities 29
6. Reset Our Relationships with States 34
7. Improve Transparency 35
8. Relevant Policies and Guidances. 35
B. SAFE DRINKING WATER ACT (SOWA) 36
1. Linkwith Top Office of Water Priorities 36
2. Aggressively Go After Pollution Problems That Make a Difference in Communities 37
4. Improve Transparency 38
5. Relevant Policies and Guidances. 38
SECTION V: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS ENVIRONMENTAL
PROBLEMS FROM WASTE, TOXICS, AND PESTICIDES POLLUTION 39
A. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) 39
1. Statutory and Regulatory Requirements 39
2. Implement National Enforcement Initiatives 40
FY2012 OECA NPM Guidance Page 2
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3. Link with Top OSWER Priorities 41
4. Aggressively Go After Pollution Problems That Make a Difference in Communities 41
5. Reset Our Relationships with States 44
6. Improve Transparency 46
B. Toxic SUBSTANCES CONTROL ACT (TSCA) 46
1. Link with Office of Chemical Safety, Pesticides, and Prevention's Top Priorities 47
3. Reset Our Relationships with States 52
4. Improve Transparency 53
5. Relevant Policies, and Guidances 54
C. FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA) 54
1. Link with Top Office of Pesticide Programs Priorities 54
2. Aggressively Go After Pollution Problems That Make a Difference in Communities 55
3. Reset Our Relationships with States 63
4. Improve Transparency 64
5. Relevant Policies and Guidances 64
D. SPECIFIC COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT (CERCLA)
ENFORCEMENT PROGRAM PERFORMANCE EXPECTATIONS 66
7. Link with Top OSWER Priorities 66
2. Aggressively Go After Pollution Problems That Make a Difference in Communities 66
3. Working With States, Tribes and Local Communities 68
4. Improve Transparency 68
SECTION VI: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS ENVIRONMENTAL
PROBLEMS THROUGH CRIMINAL ENFORCEMENT 69
1. Criminal Enforcement Priorities 69
1. Linkwith Critical Program Office Priorities 69
3. Improve Transparency 70
SECTION VII: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS ENVIRONMENTAL
PROBLEMS THROUGH THE NATIONAL ENVIRONMENTAL POLICY ACT 71
A. SPECIFIC FEDERAL ACTIVITIES PROGRAM PERFORMANCE EXPECTATIONS 71
SECTION VIII: NATIONAL PROGRAM REQUIREMENTS FOR ADDITIONAL OECA PROGRAMS
UNDER GOAL 5 73
A. SPECIFIC EMERGENCY PLANNING AND COMMUNITY RIGHT TO KNOW ACT (EPCRA) PROGRAM PERFORMANCE
EXPECTATIONS 73
1. Linkwith Top Office of Environmental Information Priorities 73
2. Aggressively Go After Pollution Problems That Make a Difference in Communities 73
3. Reset Our Relationships with States 75
4. Improve Transparency 75
5. Relevant Policies and Guidances. 75
B. COMPLIANCE INCENTIVES PROGRAM PERFORMANCE EXPECTATIONS 75
1. Aggressively Go After Pollution Problems That Make a Difference in Communities 75
2. Reset Our Relationships with States 76
3. Improve Transparency 76
C. FEDERAL FACILITIES ENFORCEMENT PROGRAM PERFORMANCE EXPECTATIONS 76
1. Aggressively Go After Pollution Problems That Make a Difference in Communities 77
2. Reset Our Relationships with States 79
3. Improve Transparency 79
D. STATE REVIEW FRAMEWORK (SRF) EXPECTATIONS 79
SECTION IX. FY2012 OECA WORKPLAN SUBMISSION INSTRUCTIONS 81
A. ANNUAL COMMITMENT SYSTEM 81
B. FTE RESOURCE CHARTS 81
SECTION X. LIST OF ACRONYMS 83
FY2012 OECA NPM Guidance Page 3
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EXECUTIVE SUMMARY
A. Program Office
This guidance applies to the Office of Enforcement and Compliance Assurance (OECA), all
Environmental Protection Agency (EPA) regional enforcement programs, and States and Tribes
implementing EPA-approved inspection and enforcement programs1. OECA designs, develops,
implements and oversees national enforcement programs, while the regional offices work with
States, Tribes, and others to implement these programs. The OECA National Enforcement
Program Managers Guidance (NPMG) for fiscal year (FY) 2012 describes how EPA should
work with state and tribal governments to enforce environmental laws that protect and improve
the quality of the Nation's environment and public health.
B. Introduction/ Context
EPA's national enforcement and compliance assurance program is multi-media in scope and
breadth. The national program maximizes compliance with ten distinct federal environmental
statutes using a variety of tools, including civil and criminal enforcement, compliance assistance,
incentives, and monitoring, as well as other strategies to improve compliance, such as
publication of compliance information. OECA implements a total of 28 separate program areas
dealing with prevention and control of air pollution, water pollution, hazardous waste, toxic
substances, and pesticides. The statutory and regulatory requirements of these programs apply to
a diverse universe of regulated entities. EPA works closely with the states to assure that
enforcement programs achieve the protections of the environmental laws and provide a level
playing field for responsible businesses.
The majority of the work in the FY 2012 NPMG is accomplished under Goal 5 - "Enforcing
Environmental Laws" in the FY 2011-2015 EPA Strategic Plan
(http://www.epa.gov/planandbudget/strategicplan.html. Goal 5 of the Strategic Plan addresses
how EPA will address pollution problems through vigorous and targeted civil and criminal
enforcement, promote compliance and deter violations by achieving set enforcement goals,
including those for national enforcement initiatives with special emphasis on potential
environmental justice concerns and those in Indian country.
The FY 2012 NPMG is organized to describe, for each statutory authority, the national
enforcement and program office priorities, and other key enforcement actions to achieve EPA's
enforcement goals.
C. Program Priorities
OECA's work aligns with and implements the Administrator's priorities in the following ways:
1 EPA implements programs in states and Indian country until EPA approves the state or Tribe to implement the
inspection and enforcement program.
FY2012 OECA NPM Guidance Page 4
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Taking Action on Climate Change: Enforcement supports the Agency's climate strategy
by recognizing reductions of global warming pollution in settlements of enforcement
actions. OECA will be working to support the integrity of the monitoring and reporting
system for global warming pollution by assuring compliance with the greenhouse gases
reporting rule.
Improving Air Quality: Enforcement helps improve air quality in communities by
targeting large pollution sources, especially in the utility, acid, cement and glass
industries, and taking aggressive action to bring them into compliance, which may
include installing controls that will benefit communities and improve emission
monitoring. OECA is working closely with the Office of Air and Radiation to reduce
toxic air pollution, through protective enforcement, permitting and standards, especially
in communities that are disproportionately affected by pollution now. OECA will
continue to work with States and Tribes to improve monitoring of compliance with air
pollution standards and make sure that action is taken against serious violations that
affect community air quality.
Assuring the Safety of Chemicals: As the Agency steps up its review of chemical safety
and pushes for reform, OECA will work closely with the Office of Chemical Safety and
Pollution Prevention to achieve its goals. The enforcement program will take action
when we find violations of standards for high-concern chemicals.
Cleaning Up Our Communities: Enforcement ensures that parties responsible for
contamination step up to their cleanup responsibilities. By ensuring that the polluter pays
whenever possible, OECA's efforts result in more cleanups, which protect more
communities from exposure and returns properties to productive use. OECA will also
use enforcement to spur cleanup at RCRA corrective action sites where the cleanup
progress is stalled.
Protecting America's Waters: OECA is revamping the water enforcement program to
focus on the problems that are the biggest threat to the nation's waters. At the same time,
OECA will increase oversight of the States and work to define the shared accountability
of EPA, States and Tribes for clean water, working closely with the Office of Water.
OECA will improve transparency, to enlist the public in holding sources and government
accountable.
Expanding the Conversation on Environmentalism and Working for Environmental
Justice: In all OECA's enforcement work, as described above, OECA can help protect
communities by targeting enforcement in areas where we find serious noncompliance and
where communities face multiple pollution threats. OECA works with other federal
agencies to make sure environmental justice considerations are included in their decision-
making process as they prepare environmental analyses (environmental impact
statements or environmental assessments) under the National Environmental Policy Act
(NEPA). OECA also will make available more understandable information on facility
compliance and government response, so that people have the information they need to
take action to improve their own communities.
FY2012 OECA NPM Guidance Page 5
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Building Strong State and Tribal Partnerships: EPA shares accountability with States and
Tribes for protecting the environment and public health. With the current economic
challenges, it is important that EPA and its partners work efficiently and effectively to do
the most we can with the resources we have. At the same time, OECA will strengthen
oversight of States that implement federal environmental programs, and support States
that take strong enforcement action to protect their citizens by making sure that we hold
all States to a comparable standard.
OECA's overall enforcement goals for FY 2012 are to:
Aggressively go after pollution problems that make a difference in communities. EPA will
use vigorous civil and criminal enforcement that targets the most serious water, air and
chemical hazards; and advance environmental justice by protecting vulnerable communities.
o Clean water
The Clean Water Act action plan commits EPA to revamp enforcement and
work with permitting to focus on the biggest pollution problems, such as
Getting raw sewage out of the water
Cutting pollution from animal waste
Reducing polluted storm water runoff
Assure clean drinking water for all communities, including in Indian country
Clean up great waters that matter to communities, e.g, Chesapeake Bay
o Clean air
Cut toxic air pollution in communities
Reduce air pollution from largest sources, including coal-fired power plants,
cement, acid and glass sectors
o Climate and clean energy
Assure compliance with Greenhouse Gas Reporting Rule
Encourage greenhouse gas emission reductions through settlements
Target energy sector compliance with air, water and waste rules
o Protect people from exposure to hazardous chemicals
Prevent releases of hazardous chemicals that threaten public health or the
environment
Press for prompt cleanup of hazardous sites in communities, ensuring that the
polluter pays
Reform chemical management enforcement and reduce exposure to pesticides,
focusing on specific areas aimed to help achieve clean water, clean air, and
climate and clean energy, and to protect people from exposure to hazardous
chemicals.
Reset our relationship with States to make sure we are delivering on our joint
commitment to a clean and healthy environment.
o Shared accountability
Make joint progress with States and Tribes toward clean air and water goals,
and protection from exposure to hazardous chemicals
FY2012 OECA NPM Guidance Page 6
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Work toward shared focus on protecting vulnerable communities
o Strengthened oversight
Assure strong and effective State enforcement of federal environmental laws
Press for consistent enforcement across States and Regions, ensuring fairness
and a level playing field
o Establish new model for shared accountability and strengthened oversight, starting
with water
Build focus on highest priority problems into grants, enforcement and
permitting agreements
Define clear expectations for state performance
Take federal action where minimum expectations are not met
Improve transparency
o Make meaningful facility compliance information available and accessible using 21st
century technologies
o Hold government accountable through public information on state and federal
performance
o Promote better federal environmental decisions and public engagement through
NEPA
To help implement these enforcement goals, OECA selects a limited number of National
Enforcement Initiatives based upon significant environmental risks and noncompliance patterns.
In FY 2010, EPA re-examined the existing initiatives to look for opportunities to clarify goals
and measures, more accurately identify universes of sources, and, where necessary, to change the
focus of an Initiative. In addition, EPA considered candidates for new National Enforcement
Initiatives. After consulting with EPA programs and Regions, States, Tribes, and the public,
OECA adopted the following National Enforcement Initiatives for 2011 through 2013. More
information on each is found in the media sections of this guidance:
Keeping raw sewage and contaminated stormwater runoff out of our waters
Cutting animal waste to protect surface and ground waters
Reducing widespread air pollution from the largest sources, especially the coal-fired
utility, cement, glass, and acid sectors
Cutting toxic air pollution that affects communities' health
Assuring energy extraction sector compliance with environmental laws
Reducing pollution from mineral processing operations
Strategies to implement these initiatives are developed by regional and headquarter teams and
include goals, measures, and options for innovative approaches.
D. Achieving Compliance for National and Regional Priorities
EPA and states need to consider how to best use the mix of compliance tools to address all the
regulated entities contributing to the environmental problem. The strategic use of the tools along
with the identification of partners to help implement them will allow for the efficient use of
Agency resources and effective approaches to solving large scale issues.
FY2012 OECA NPM Guidance Page 7
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Strategic use of the tools will benefit EPA and states by: 1) targeting limited inspection and
enforcement resources on the bad actors; 2) building capacity and coordination across partners;
and 3) expanding governments' presence and demonstrating governments' commitment. More
information on the use of integrated strategies is found in the Guide for Addressing
Environmental Problems: Using an Integrated Strategic Approach (March 2007)
http://www.epa.gov/compliance/resources/policies/assistance/index.html
Program Reviews
OECA monitors regional and state activities in a set of annual commitments at mid-year and at
the end of a fiscal year based upon Region and State results entered in OECA databases, the
Annual Commitment System (ACS), and data collected in the implementation of national
enforcement initiatives. In addition, OECA senior managers conduct an annual program review
of each regional office. The performance expectations and activities outlined in this guidance
are the starting point from which headquarters and the regional offices engage to discuss the
management of program activities and the distribution of resources. These discussions result in
regional commitments for a specific level of activity and an agreed-upon approach between the
regions and the national program manager for achieving performance expectations for the fiscal
year.
Regional Priorities
EPA Regions may also have priorities that are specific for a particular environmental situation
that may not affect other regions. Some problems cross regional boundaries and regions are
working together to address them. For example, in response to the President's May 12, 2009,
Executive Order 13508Chesapeake Bay Protection and Restoration, Regions 2, 3, 4, and 5 are
working with OECA to address nitrogen deposition to the Bay from large industrial air sources
of NOX. The Regions will build on work already begun under the national enforcement
initiatives to evaluate the compliance of power plants and other industrial sources in the
Chesapeake Bay air shed emitting more than 1000 tons of NOX per year. Any resulting
enforcement actions would seek to achieve significant NOX reductions through complying
actions, as appropriate. In addition, Region 3 will take steps to evaluate the potential impacts on
the Bay of ammonia (NFL?) emissions from concentrated animal feeding operations (CAFOs).
E. Cross Cutting Strategies in the FY2011-2015 Strategic Plan
As part of the FY 2011-2015 Strategic Plan, the Agency has identified five cross-cutting
fundamental strategies designed to change the way the Agency works and delivers environmental
and human health protection. OECA's NPM guidance directly supports three of the five cross-
cutting strategies by instructing the regions to undertake activities in FY2012 that contribute to
the cross-cutting strategies' goals. Specific examples in the FY2012 guidance include the
following:
FY2012 OECA NPM Guidance Page 8
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Expanding the Conversation on Environmentalism
Data regarding state assessments, priorities and performance under the Clean Water Act
(CWA) should be made public, where possible, on a regular basis in a manner easily
understood and used by the public;
Compliance data should distinguish State information from Indian country information;
Information should be made available to communities, including Native American and
Alaskan Natives, who lack access to the internet;
Criminal Enforcement program will continue to develop its use of new outreach methods
such as Facebook, Twitter and mobile applications to encourage the public's reporting of
potential violations and to provide leads through the fugitives website
http ://www. epa.gov/fugitives/.
Strengthening State, Tribal and International Partnerships
Regions will continue to implement the CWA Action Plan in FY2012 by collaborating with
states to address NPDES permitting, compliance monitoring, and enforcement activities,
including work-sharing;
A majority of program narratives in the FY2012 guidance contain specific activities
regarding state relationships;
Regions should consult, as appropriate, with potentially impacted tribal governments when
conducting inspections and addressing noncompliance at tribal and non-tribal facilities in
Indian country.
Working for Environmental Justice (EJ) and Children's Health
Regions are directed to use the Agency's environmental justice tools and methodologies to
focus enforcement and compliance efforts in communities overburdened by exposure to
environmental risks, including minority and low-income communities, as well as those with
greater concentrations of sensitive populations.
Specific OECA EJ performance expectations, which include children's health as appropriate,
are discussed in Section II of this guidance.
OECA's national enforcement initiatives address some of the more complex pollution problems;
especially those confined to a particular sector or source type, and can have positive impacts
on children's health. For example:
o Reducing widespread air pollution from large sources, especially the coal-fired utility,
cement, glass, and acid sectors can potentially lessen adverse health effects such as
asthma, respiratory diseases and premature death in communities overburdened by
exposure to environmental risks and vulnerable populations, including children.
o Preventing animal waste from contaminating surface and ground waters reduces
children's exposure to disease-causing pathogens, nutrients, or other contaminants which
have potential adverse health effects
o Addressing the human health and environmental threats from of mining and mineral
processing can lead reduced exposure to asbestos and lead poisoning in children.
In addition to the national initiatives, OECA reduces risks to children through the following:
FY2012 OECA NPM Guidance Page 9
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o Requiring Local Education Agencies (LEAs) to inspect for asbestos
o Monitoring and enforcement to promote compliance with lead based paint (LBP) rules to
advance the goal of eliminating and preventing LBP hazards, which are the primary cause
of childhood lead poisoning.
o Monitoring and enforcement to prevent the illegal importation of pesticides which have
been linked to poisoning of children
F. Significant Changes from FY2011
The Office of Enforcement and Compliance Assurance's FY 2012 guidance continues to focus
on the Administrator's and Assistant Administrator's goals, and on aligning enforcement and
compliance priorities with those of the other EPA national program managers. As in FY 2011,
the FY 2012 guidance is organized to describe the specific expectations for Regions that
implement the Assistant Administrator's priorities and, explains how the enforcement program
supports the priorities of other EPA national programs. There are some notable changes in
specific programs contained within this guidance and can be summarized as follows:
Clean Water Action Plan: The FY12 guidance contains more specific instructions for the
regions and states on how to implement the Clean Water Action Plan such as replacing
existing paper reporting with electronic reporting, creating a new compliance paradigm,
retooling key NPDES permitting and enforcement activities, and conducting comprehensive
and coordinated permitting, compliance, and enforcement programs.
Wetlands Program: The FY12 guidance sets expectations for the regions to participate in a
Section 404 Enforcement Strategy pilot program to improve coordination and
communication between EPA and the Corps of Engineers to improve management of the
wetlands protection program.
Oil Spills Prevention: In light of the events of the British Petroleum oil spill, the FY12
guidance has been expanded to provide more detailed instructions on the compliance and
enforcement activities of an effective oil spill program.
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Program - Each year
regions are asked to place special emphasis on key focus areas within the FIFRA program.
In FY12, an optional focus area has been included to provide flexibility to the regions on
where to focus their efforts. This flexibility allows for more opportunities to support the
Office of Chemical Safety and Pollution Prevention's program priorities.
G. Contacts
For general questions or comments on the OECA National Program Managers Guidance or our
Annual Commitments please contact:
FY2012 OECA NPM Guidance Page 10
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Lisa Raymer
Office of Enforcement and Compliance Assurance
Office of Compliance
Planning, Measures, and Oversight Division
1200 Pennsylvania Ave., NW, M2221A
Washington, DC 20460
Email: Raymer.Lisa@epa.gov
FY2012 OECA NPM Guidance Page 11
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SECTION I: OECA GUIDANCE DEVELOPMENT AND FEEDBACK PROCESS
OECA has structured the NPM Guidance to focus on the performance expectations of the
national enforcement program in terms of 1) achieving the Enforcement Goals, 2) making
progress in attaining compliance within the national enforcement initiative areas and 3)
supporting the EPA program offices in achieving their environmental and public health goals.
EPA will post the FY 2012 NPM draft Guidance to allow Regions, States, Tribes, and others to
review and comment on the draft. In the past, OECA has received comment from Regions,
States, Tribes, and other stakeholders. OECA will respond to the comments and incorporate
changes, as needed, in the final documents. The final guidance and a Response to Comments
Summary will be posted on the Internet showing the action taken in the final guidance as a result
of comments.
SECTION II: SPECIFIC ENVIRONMENTAL JUSTICE PROGRAM PERFORMANCE
EXPECTATIONS
OECA plays a dual role in setting performance expectations for environmental justice. First,
OECA oversees national and regional enforcement programs. In this role, OECA ensures that
facilities in communities overburdened by environmental problems are complying with the law.
OECA aggressively applies regulatory tools to protect vulnerable communities, enlists partners
to meet community needs, and fosters community involvement in EPA's decision-making
processes by making information available.
Second, OECA is the National Program Manager for the Environmental Justice (EJ) Program.
The EJ Program facilitates headquarter and regional efforts to achieve measurable environmental
or public health benefits/results for communities overburdened by environmental problems.
OECA and Region 5, as Lead Region for FY2011-2013, are implementing the Strategies and
Activities outlined in Advancing Environmental Justice through Enforcement and Compliance
(EJ 2014 Plan), one of the five cross-cutting areas identified for Agency-wide action in EPA's
Plan EJ 2014. OECA's goals under this Plan are to fully integrate consideration of EJ concerns2
into the planning and implementation of program strategies, case targeting strategies, and
development of remedies in enforcement actions to benefit these communities. OECA also plans
to accelerate efforts to communicate more effectively with vulnerable and overburdened
communities about enforcement actions and program activities.
2 EPA defines "environmental justice" as the fair treatment and meaningful involvement of all people regardless of
race, color, national origin, or income with respect to the development, implementation, and enforcement of
environmental laws, regulations, and policies. EJ concerns with respect to "fair treatment" arise where there are
actual or potential disproportionate impacts on minority, low-income, or indigenous populations that exist prior to or
that may be created by a proposed action. EJ concerns with respect to "meaningful involvement" arise where there is
an actual or potential lack of opportunities for minority, low-income, or indigenous populations, or tribes, to
effectively and appropriately participate in decision-making. These terms are discussed in more detail in Part I of
EPA's "Interim Guidance on Considering Environmental Justice during the Development of an Action "
(http://www.epa.gov/compliance/ej/resources/policy/ej-rulemaking.html).
FY2012 OECA NPM Guidance Page 12
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OECA has developed five strategies for Advancing Environmental Justice through Enforcement
and Compliance:
1. Advance EJ goals through selection and implementation of National Enforcement
Initiatives.
2. Advance EJ goals through targeting and development of compliance and enforcement
actions.
3. Enhance use of enforcement and compliance tools to advance EJ goals in Regions'
geographic initiatives to address overburdened communities.
4. Seek appropriate remedies in enforcement actions to benefit vulnerable and overburdened
communities and address EJ concerns.
5. Enhance communication with affected communities and the public regarding EJ concerns
and the distribution and benefits of enforcement actions, as appropriate.
For FY2012, OECA will address our EJ 2014 Plan goals through the following performance
expectations.
1. Advance EJ goals through Selection and Implementation of National Enforcement
Initiatives
OECA will continue to look for opportunities to address EJ concerns as it implements the
National Enforcement Initiatives for FY2011-13. A "Strategy Implementation Team,"
consisting of OECA headquarters and regional representatives, is responsible for developing
implementation strategies and performance measures for each of the National Enforcement
Initiatives. Each initiative's strategy will consider how EJ concerns can be addressed in
carrying out its activities, e.g. by giving priority in case selection to overburdened
communities affected by the pollution problems the Agency seeks to address in each of the
initiatives. In developing remedies in initiative's enforcement cases, the Agency will seek
judicial and administrative remedies that will reduce or eliminate pollution that may have a
disproportionate impact on minority, low-income or indigenous populations.
2. Advance EJ Goals Through Targeting and Development of Compliance and
Enforcement Actions
OECA and the Regions will place a high priority on addressing EJ concerns as the specific
targeting and case selection strategies for both National Enforcement Initiative and other
enforcement cases are developed. As discussed above, the Strategic Implementation Teams
for each Initiative have identified opportunities to protect and benefit overburdened
communities when selecting and developing specific cases to achieve the Initiative goals.
For example, when selecting specific CAFO facilities for enforcement action, priority may be
given to facilities that are impacting or threatening the drinking water supplies of poor rural
communities. OECA and the Regions will also give specific consideration and priority to
overburdened communities when selecting enforcement actions to address other important
compliance problems, regardless of whether they are part of an Initiative. For example, in
selecting enforcement actions to address violations of drinking water standards, we will give
high priority to addressing violations at water supply systems that serve poor and tribal
communities, as well as children, one of our most vulnerable populations.
FY2012 OECA NPM Guidance Page 13
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In FY2012, OECA will continue to use the Environmental Justice Strategic Enforcement
Assessment Tool (EJSEAT) or similar screening tools and other information, e.g.,
community input, to support targeting of enforcement actions and to enhance performance
reporting. In addition to OECA's efforts to develop screening tools for use in the
enforcement and compliance program, the Agency's Information Tools Development
Workgroup is undertaking a larger effort to develop guidance on identifying areas of
potential EJ concern as a separate effort under EPA's Plan EJ 2014. It will be important to
ensure that OECA's guidance to enforcement case teams is consistent with the approaches
developed by the Agency-wide EJ Screening Committee. Therefore, upon completion of the
Screening Committee's work, OECA will review its guidance to ensure that it is consistent
with the final Agency decisions based on the EJ Screening Committee's work.
Regions may be asked to support development of tools to track and report on
enforcement actions and results that impact communities with potential EJ concerns, in
ICIS, according to the instructions and pilot to be developed by the EJ Tracking and
Reporting Workgroup.
3. Enhance Use of Enforcement and Compliance Tools to Advance EJ Goals in Regions'
Geographic Initiatives to Address Overburdened Communities
Regions have developed, and continue to develop, integrated strategies to focus on particular
geographic areas in their Regions with overburdened communities that are disproportionately
affected by environmental problems. Beginning in 2008 for example, each Region identified
a "Showcase Community" to focus efforts to address EJ concerns. The Regions used
integrated strategies for this purpose that included the full range of EPA's tools, and a
number of these projects included use of enforcement and compliance assurance tools .
Under this Strategy, the Regions will ensure that they use their enforcement and compliance
assistance tools effectively to identify and address environmental problems in areas of EJ
concern that are caused or made worse by violations of federal environmental laws. For
example, EPA Regions 3, 4 and 5 are leading a geographic enforcement initiative focused on
Huntington Port, which was selected in part because screening analysis indicated a high
potential for EJ concerns. This initiative incorporates enforcement and compliance
assistance to reduce pollution and increase compliance. It also includes workshops to build
the community's capacity to help ensure the long-term protection of the environment and
public health.
Regions, together with state and other partners as appropriate, should evaluate facility
compliance in EJ communities selected for strategic focus. These evaluations should be
targeted using the best available data and methods in light of the overall objectives of
EPA's enforcement and compliance assurance work. In this way, community-focused
initiatives will complement the national enforcement initiatives and other sector-based
and program-specific enforcement activities, meeting OECA's goal of strategically using
limited enforcement resources to address the most significant issues first.
Regions should tailor compliance evaluation and enforcement actions as part of
integrated strategies to maximize EPA's ability to gain environmental benefits in
overburdened communities. For example, this could include use of multi-media
FY2012 OECA NPM Guidance Page 14
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inspections and/or process inspections to comprehensively address potential impacts from
violations at a given facility.
OECA and the Regions will consider and use compliance assistance activities to
effectively reach large numbers of small sources with environmental violations that have
significant local impacts on overburdened communities. Compliance assistance tools are
particularly appropriate, at least as an initial compliance effort, when widespread
violations are found among small businesses, which often have limited resources and less
ability than major industrial facilities to understand and comply with the requirements of
federal environmental regulations. EPA and states have often been successful in
improving small businesses' compliance with environmental regulations through focused
outreach and education efforts.
4. Seek Appropriate Remedies in Enforcement Actions to Benefit Vulnerable and
Overburdened Communities and Address EJ Concerns.
OECA and the Regions, and the Environmental Enforcement Section of the U.S. Department
of Justice (DOJ) are jointly heightening their focus in civil enforcement cases on potential
options to obtain meaningful environmental benefits to specific overburdened communities
impacted by violations of federal environmental laws. These efforts go beyond traditional
injunctive relief to stop illegal pollution, to provide for mitigation of the environmental harm
caused by illegal pollution and, where appropriate and agreed to by defendants, Supplemental
Environmental Projects (SEPs) to provide benefits to communities. For example, in a case
involving illegal discharges of pollutants from a facility that damaged a tribal fishing area,
the relief ordered (in addition to stopping the illegal discharges) included restocking the
fishing ground. EPA has also been successful in obtaining SEPs from defendants to retrofit
diesel school buses, to reduce the air pollution children are exposed to. We will continue
and accelerate these types of efforts to reduce pollution burdens that have a disproportionate
impact on minority, low-income or indigenous populations.
In addition to the benefits that can be obtained for overburdened communities through
judicial and administrative enforcement actions, there may be other, parallel opportunities in
a particular situation and community to obtain additional benefits for the community through
cooperation with other federal agencies, state or local governments, and/or the business
community. For example, the U.S. Department of Housing and Urban Development may be
able to provide housing assistance or other community benefits in a "brownfields" area
where EPA has taken enforcement action to clean up environmental contamination. State or
local governments may have projects or grant funding that can be used to improve the
community's infrastructure or environment in an area that is also the focus of EPA
compliance or enforcement action. In situations where air emissions from multiple industrial
facilities continue to adversely affect community health despite their compliance with
emission limitations, some business communities may be willing to work together to take
voluntary action to further reduce the emissions that adversely affect the community.
Examples of such voluntary actions include: a health clinic established and operated together
with local, state and community members; a household hazardous waste collection drive; a
local company voluntarily agreeing to post compliance monitoring information directly on a
public website to allow community members to check on compliance; "good neighbor
FY2012 OECA NPM Guidance Page 15
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agreements" between local companies and communities to address facility impacts not
regulated by a permit or other law. EPA will identify specific opportunities, in cases or
regional geographic initiatives, to work with other federal agencies, state and local
governments, and/or the business community to complement and leverage benefits resulting
from enforcement activities. EPA will document and share recommendations and best
practices for taking action on these opportunities.
5. Enhance Communication with Affected Communities and the Public Regarding EJ
Concerns and the Distribution and Benefits of Enforcement Actions, As Appropriate
OECA and the EPA Regions with the Department Of Justice will increase their efforts to
communicate with affected communities and the public about enforcement strategies and
actions that may affect vulnerable and overburdened communities. We recognize that
communities have a legitimate need to be informed and to understand the federal
government's enforcement activities to protect their environment, and to have their voices
heard when solutions are being considered to redress environmental problems caused by
violations of federal environmental laws that affect their community. As OECA implements
Plan EJ 2014, we commit to increase our outreach to communities and to provide more
information about environmental problems caused by failure to comply with federal
environmental laws, our efforts to address those problems, and available judicial and
administrative solutions to those problems that can address the communities' concerns and
needs.
At the same time, it is important for communities to understand the legitimate and essential
need to protect the confidentiality of enforcement activity when a case is under development
and in settlement negotiations. This is essential to assure that effective enforcement, and its
ultimate benefits for the community, will not be undermined and adversely affected by
premature disclosure of confidential enforcement information. While this consideration will
necessarily limit the amount and kind of information that EPA is able to share with the
community at various stages of enforcement activity, we are committed to sharing as much
information as possible to enable communities to be informed and to have their voices heard
in the determination of appropriate resolutions for violations of federal environmental laws
that affect communities.
While increased communication efforts are important, it is no less important to receive input
from communities on potential violations. We will continue to invite tips and complaints,
including through such means as OECA's on-line reporting badge and the EPA fugitives
webpage.
OECA and the Regions will review their enforcement dockets to identify communities
with EJ concerns that could benefit from enhanced communication and consultation
regarding enforcement activities, and provide the communities with additional
information (consistent with the confidentiality requirements needed to protect the
integrity of enforcement actions).
OECA and the Regions will also provide opportunities for communities to provide input
on EJ concerns and remedies to be sought in enforcement actions that affect their
FY2012 OECA NPM Guidance Page 16
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communities. This information will be provided through EPA's website, local
information repositories, and other appropriate means.
OECA and the Regions recognize that EPA's enforcement processes, e.g. the
enforcement processes concerning hazardous waste site cleanup that affect communities
with EJ concerns, are often complicated and can be difficult for the public to understand
and to follow. To increase communities' ability to understand our enforcement
processes, we will continue to improve the accessibility to communities of the
information provided on EPA's website, develop and make available fact sheets to better
explain EPA's enforcement process at particular sites, and update for internal EPA use a
compendium of "best practices" that will encourage and facilitate EPA employees'
efforts to make enforcement information more available to the public. EPA's
enforcement actions frequently provide significant benefits1 to vulnerable and
overburdened communities, including reduction of air or water pollution, cleanup of toxic
and hazardous waste, and additional community benefits such as diesel bus retrofits and
other benefits made available through Supplemental Environmental Projects (SEPs).
However, the community is able to appreciate these benefits only to the extent that it is
aware of them. Therefore, OECA and the Regions will continue accelerating our efforts
to communicate, through press releases, our website and other means, the benefits of our
enforcement actions for vulnerable and overburdened communities, consistent with the
memo, "Characterizing the EJ Benefits Achieved in Enforcement Actions" issued in
2011.
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SECTION III: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS
ENVIRONMENTAL PROBLEMS FROM AIR POLLUTION
A. Clean Air Act (CAA)
OECA addresses air pollution problems through the following CAA programs:
Part 60 - New Source Performance Standards (NSPS)
Part 61- National Emission Standards for Hazardous Air Pollutants (NESHAP)
Part 63 -Maximum Achievable Control Technology (MACT)
o Maximum Achievable Control Technology (MACT) - major sources
o Generally Available Control Technology (GACT) - area sources
New Source Review/Prevention of Significant Deterioration (NSR/PSD)
Enforcement of State Implementation Plans and plans developed and approved under
Section lll(d)
Title V Operating Permits
Part 82-Title VI Stratospheric Ozone Protection
Section 112(r) Prevention of Accidental Releases
Title n (Emission Standards for Moving Sources)
Section 129 Solid Waste Combustion
1. Implement National Enforcement Initiatives
The relevant FY 2011 - 2013 national enforcement initiatives for CAA programs are:
Cutting Toxic Air Pollution that Affects Communities' Health: In 1990, Congress identified
189 hazardous air pollutants (HAPs) that present significant threat to human health and have
adverse ecological impacts (http://www.epa.gov/ttn/atw/188polls.html). The pollutants are
known or suspected to cause cancer and other serious health effects, such as reproductive or birth
defects. The threats posed by HAPs may be particularly significant for communities
overburdened by exposure to environmental risks, including urban minority and low-income
communities, as well as those with greater concentrations of sensitive populations. The CAA and
EPA's regulations impose strict emission control requirements (known as "Maximum
Achievable Control Technology" or "MACT") for these pollutants, which are emitted by a wide
range of industrial and commercial facilities. For FY2011-13, EPA will target and reduce
emissions of toxic air pollutants in three areas where the Agency has determined there are high
rates of noncompliance: (A) leak detection and repair; (B) waste gas flares; and (C) excess
emissions, including those associated with startup, shut down and malfunction. Particular
emphasis will be given to emissions at sources that have a significant impact on air quality and
health in communities. As part of this effort, OECA will utilize innovative monitoring and
evaluation techniques and partner with EPA's Office of Air and Radiation (OAR) and Office of
Research and Development.
Reducing Widespread Air Pollution from the Largest Sources, Especially the Coal-fired
Utility, Cement, Glass, and Acid Sectors: The NSR/PSD requirements of the CAA require
FY2012 OECA NPM Guidance Page 18
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certain large industrial facilities to install state-of-the-art air pollution controls when they build
new facilities or make "significant modifications" to existing facilities. However, many
industries have not complied with these requirements, leading to excess emissions of air
pollutants such as sulfur dioxide, nitrogen oxides and particulate matter. These pollutants can be
carried long distances by the wind and can have significant adverse effects on human health,
including asthma, respiratory diseases and premature death. These effects may be particularly
significant for communities overburdened by exposure to environmental risks and vulnerable
populations, including children. In recent years, EPA has made considerable progress in reducing
excess pollution by bringing enforcement actions against coal-fired power plants, cement
manufacturing facilities, sulfuric and nitric acid manufacturing facilities, and glass
manufacturing facilities. However, work remains to be done to bring these sectors into
compliance with the CAA and protect communities burdened with harmful air pollution.
Therefore EPA will continue this work as a National Enforcement Initiative for FY2011-2013.
As of January 2, 2011, EPA also began regulating greenhouse gases (GHGs) under its NSR
program. EPA will endeavor to ensure these pollutants are also addressed in any process
changes or modification that gives rise to NSR requirements.
Assuring Energy Extraction Sector Compliance with Environmental Laws: As the nation
expands its search for new forms and sources of energy, there is an urgent need to assure that we
develop "clean energy" sources that protect our air, water and land. Some energy extraction
activities, such as new techniques for gas extraction, pose a risk of pollution of air, surface
waters and ground waters if not properly controlled. For example, an unprecedented acceleration
of natural gas leasing and development has led to a significant rise in the level of air pollution
throughout the intermountain West. Drilling and fracking activities have led to concerns about
ground water pollution and the safety of drinking water supplies in various parts of the country.
To address these emerging problems, OECA's energy extraction initiative will focus on efforts to
assure that natural gas extraction activities are complying with federal requirements to prevent
pollution of our air, water and land. This initiative will be undertaken in particular areas of the
country where natural gas extraction activities are concentrated, and the focus and nature of our
enforcement activities will vary with the type of activity and pollution problem presented.
2. Link with Top Office of Air and Radiation Priorities
OECA addresses top OAR priorities in the following ways:
Greenhouse Gases (GHG): OECA continues to support the Agency's climate strategy by
recognizing reductions of global warming pollution in settlements of enforcement
actions. OECA and OAR will implement a National Implementation Strategy for the
Greenhouse Gas Reporting Program. The National Implementation Strategy will provide
guidance to Regions on compliance monitoring and assistance activities, in order to
establish the appropriate enforcement response to support the integrity of the GHG
monitoring and reporting system. As noted above, OECA will also ensure that sources
undertaking certain process changes or modification that result in significant GHG
emissions go through proper New Source Review permitting.
FY2012 OECA NPM Guidance Page 19
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Air Toxics in Communities: OECA will address this Agency priority through the 2011 -
2013 National Enforcement Initiative - cutting toxic air pollution that affects
communities' health. OECA also is working closely with OAR and ORD to reduce toxic
air pollution through standards, permitting, compliance monitoring and assistance
activities, and enforcement, especially in communities overburdened by environmental
problems.
3. Aggressively Go After Pollution Problems That Make a Difference in Communities
Air pollution moves with the wind and is therefore of great concern to communities both near its
source and remotely located. Air pollutants that are emitted closer to the ground, for example as
a result of equipment leaks or low stack height, can cause disproportionate exposure for
neighboring communities. In industrial areas, these communities frequently have significant low
income and minority populations. Serious health effects caused by air pollution include
difficulty in breathing, exacerbation of respiratory and cardiac conditions, and cancer.
Regions and delegated state/local agencies and Tribes should:
Implement programs in accordance with existing national compliance and enforcement
policy and guidance (e.g., the CAA Stationary Source Compliance Monitoring Strategy
(CMS); the CAA National Stack Testing Guidance, the Timely and Appropriate Enforcement
Response to High Priority Violations (HPV Policy); and the Area Source Implementation
Guidance to address significant air pollution problems that adversely affect impacted
communities by reducing such pollution from the largest sources with special attention
directed toward reducing toxic air pollution. Regions should work with delegated
agencies/tribes to ensure that they are familiar with national guidance, aware of the
flexibilities within the guidance, and implement their programs consistent with the guidance.
To identify the most important air pollution problems and the most serious violations, use
targeting tools and other information, such as the Environmental Justice Strategic
Enforcement Assessment Tool (EJSEAT), and community input.
Have a clearly defined process for identifying, targeting, evaluating, prioritizing, and
responding to CAA violations.
Work together to initiate civil and criminal enforcement actions, as appropriate, and
whenever necessary to protect communities by addressing and ultimately resolving serious
air violations in order to bring sources into compliance.
Evaluate all violations, determine an appropriate response, and take timely and appropriate
actions against facilities determined to have High Priority Violations (HPV).
Enter data on all federally-reportable violations, not just HPVs, consistent with the
'Clarification Regarding Federally-Reportable Violations for Clean Air Act Stationary
Sources" ("2010 FRV Clarification") issued on March 22, 2010.
Negotiate settlements and track compliance with consent decrees and administrative orders
and take all necessary actions to ensure compliance with the terms of federal enforcement
actions.
Utilize compliance assistance, monitoring, enforcement tools and other approaches that are
effective in achieving widespread compliance; the appropriate combination and sequencing
FY2012 OECA NPM Guidance Page 20
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of compliance assistance and enforcement tools may vary with the CAA program and the
type of regulated industry.
In addition, the Regions should:
Continue any on-going investigations and initiate new ones, as appropriate. Activities
reported as investigations should meet the definition of an investigation as provided in the
CMS and minimum data requirements. Regions must review and approve state
implementation plans (SIPs) as well as to track the compliance status of sources within
various regulatory programs under the Clean Air Act. Both initiated and completed
investigations are to be reported in AFS.
Review Title V permits consistent with national guidance and ensure the delegated
agencies/tribes are reviewing the certifications consistent with the CMS. Regions also
should ensure that Title V permits do not shield sources subject to a pending or current CAA
enforcement action or investigation, and that draft Title V permits include appropriate
placeholder language for the applicable requirement at any affected units. Regions should
ensure that consent decree requirements, including required schedules of compliance are
incorporated into underlying federally enforceable non-Title V and Title V permits.
Include evaluations of the proper use and disposal of ozone-depleting chlorofluorocarbons
(CFCs), hydrochlofluorocarbons (HCFCs), halon fire suppressants and other ozone depleting
substances (ODS) as part of routine full compliance evaluations (FCEs)/partial compliance
evaluations (PCEs) to the extent the regulations apply.
Inspect federal facilities, initiate enforcement actions to address non-compliance at federal
facilities, and seek penalties, where appropriate, consistent with the 1997 penalty policy for
CAA violations by federal agencies.
Perform CAA section 112(r) inspections at regulated facilities in the Region, including high
risk facilities. A high risk facility is one which meets one or more of the following criteria:
1) any facility which has reported worst-case scenario population that exceeds 100,000
people based on the Risk Management Program (RMP); 2) any RMP facility with a hazard
index greater than or equal to 25; and/or; 3) any facility that has had one or more significant
accidental releases within the previous five years. (Note: facilities that have only program
one process are not considered high risk). Inspections at high-risk facilities should also
include an evaluation of compliance with applicable EPCRA and CERCLA requirements.
Evaluate facilities that experience significant chemical accidents to determine compliance
with CAA sections 112(r)(l) and (7) and pursue an appropriate enforcement response for any
violations.
Conduct CAA section 112(r) inspections in accordance with the recently issued "Guidance
for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)"
which updated and superseded the "Guidance for Auditing Risk Management
Plans/Programs under Clean Air Act Section 112(r) of August 1999. This document
establishes final EPA policy on involvement of facility employees and employee
representatives in EPA and delegated agency on-site compliance inspections as provided for
in CAA section 112(r)(6)(L).
Focus on identifying RMP non-filers and initiating enforcement in accordance with the June
30, 2010 memorandum titled 'Identification of Facilities Subject to 40 CFR Part 68'.
Work to bring 100% closure to any self-disclosure received by the Region.
FY2012 OECA NPM Guidance Page 21
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Settle or litigate cases filed in years prior to FY2012.
Exercise authority in accordance with the 2008 Civil Monetary Penalty Inflation Adjustment
Rule and the Amendments to the CAA Civil Penalty Policy.
Ensure compliance with environmental statutes in Indian country unless and until a Tribe
obtains primacy.
COMMITMENT CAA04: The number of compliance evaluations to be conducted by the
regions at majors sources, 80% synthetic minors, and other sources (as appropriate). [Note:
Region should break out evaluation projections by source classification and by compliance
monitoring category (FCE, PCE, and Investigations). In the comment section, each region should
also provide the number of federal facility FCEs, PCEs and investigations. Projected
investigations under this commitment are those investigations initiated by the Regions for the air
enforcement program outside of the National Enforcement Initiatives, and identified by the air
program (e.g., MACT, NSPS).
4. Reset Our Relationships with States
The Regions should work with the state/local agencies and Tribes to identify priorities and align
resources to implement the above commitments. This includes:
Holding annual planning meetings with senior federal and state management to discuss air
quality standards, permitting, and enforcement when developing program goals and annual
monitoring and enforcement work plans. Convening routine and regular (several times per
year) meetings with senior state management to assess progress in how the State has been
performing overall in its implementation of the program. These meetings may be held in
person or through conference calls or other venues, as appropriate. Regular frequency of
these meetings is strongly suggested as a best practice for ensuring progress in meeting goals.
Where a state is not meeting performance expectations, the Regions should take enforcement
actions to address serious violations, particularly in the absence of an appropriate response by
the state. The Regions should focus oversight resources to the most pressing performance
problems in states and should work to demonstrably improve state performance through these
actions. The Regions need to take action when necessary to communicate which issues need
attention to achieve the goals of the federal environmental laws and ensure a level playing
field between States. Ensuring delegated agencies implement compliance monitoring and
enforcement programs in accordance with national guidance/policy (e.g., the CAA CMS;
HPV Policy; CAA National Stack Testing Guidance; Area Source Implementation
Guidance). The Regions should monitor the level and quality of efforts undertaken by the
delegated agencies to ensure strong enforcement of environmental laws. Enforcement
actions, whether taken by the Regions, delegated states/locals, or Tribes should be timely,
appropriate, and accurately reported.
Negotiating facility-specific CMS plans with all delegated agencies. Throughout the year,
the Regions are to be evaluating progress and working with delegated agencies to revise such
CMS plans as necessary.
Having frequent (at least monthly) discussions with delegated agencies to ensure consistent
implementation of the HPV Policy.
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Implementing the State Review Framework for the CAA Program and ensuring progress with
corrective actions identified in the SRF reports.
Consulting with Tribes on the central role that enforcement and compliance plays in EPA's
direct implementation program and oversight of approved tribal programs.
COMMITMENT CAA06: Ensure that delegated state agencies implement their compliance and
enforcement programs in accordance with the CAA CMS and have negotiated facility-specific
CMS plans in place. The Regions are to provide the number of FCEs at majors and 80%
synthetic minors to be conducted by individual state/local agencies to demonstrate program
implementation consistent with CMS. However, if a delegated agency negotiates with a Region
an alternative CMS plan, this Commitment should reflect the alternative plan. [Note: Break out
evaluation projections (e.g., FCEs; PCEs included in alternative plan) by source classification].
Prior to approving an alternative plan, Regions should consult with the Office of Compliance
(OC) and provide OC with information on how the state/local agency compliance monitoring air
resources will be redirected and the rationale for making the change.
5. Improve Transparency
The Regions should:
Work with the state/local agencies and Tribes to verify that their compliance and
enforcement data is added to the Air Facility System (AFS), the national repository for air
stationary source compliance monitoring and enforcement data.
Enter complete, accurate, and timely data consistent with the AFS Information Collection
Request (ICR) and Agency policies. Agreements with delegated agencies to provide
complete, accurate, and timely data should be incorporated in documents such as
memorandum of understanding (MOU), State Enforcement Agreements (SEAs),
Performance Partnership Agreements (PPAs)/ Performance Partnership Grants (PPGs) or
Section 105 grant agreements.
Work with EPA Headquarters to modernize AFS.
COMMITMENT CAA07: The Regions and delegated agencies should enter 100% of MDRs in
AFS consistent with Agency policies, including the 2010 FRV Clarification, and the AFS ICR.
The reporting of such complete, accurate, and timely data by delegated agencies should be
reflected in written, up-to-date agreements with the Regions. If the Region is responsible for
entering data for a delegated agency or Tribe, the Region should identify the delegated agency or
Tribe.
6. Relevant Policies and Guidances
Additional information about OECA's CAA programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/caa/index.html
http://www.epa.gov/compliance/civil/caa/index.html
List of relevant CAA policies and guidance:
FY2012 OECA NPM Guidance Page 23
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The Air Facility System Business Rules Compendium
www.epa.gov/compliance/resources/policies/data/systems/air/afsbusinessrulescompendium.p
df
The Air Facility System Minimum Data Requirements
www.epa.gov/compliance/resources/publications/data/systems/air/mdrshort.pdf
CAA Stationary Source Compliance Monitoring Strategy
www.epa.gov/compliance/resources/policies/monitoring/cmspolicy.pdf
CAA National Stack Testing Guidance
www.epa.gov/compliance/resources/policies/monitoring/caa/stacktesting.pdf
Area Source Rule Implementation Guidance
http://www.epa.gov/compliance/resources/policies/monitoring/caa/areasource.pdf
The Timely and Appropriate Enforcement Response to High Priority Violations
www.epa.gov/compliance/resources/policies/civil/caa/stationary/issue-ta-rpt.pdf
The Timely and Appropriate Enforcement Response to High Priority Violations Workbook
www.epa.gov/compliance/resources/policies/civil/caa/stationary/hpvmanualrevised.pdf
CAA Stationary Source Civil Penalty Policy
www.epa.gov/compliance/resources/policies/civil/caa/stationary/penpol.pdf
CAA Section 112(r) Combined Enforcement Policy
http://epa.gov/compliance/resources/policies/civil/caa/stationary/caall2r-enfpol.pdf
Guidance for Conducting Risk Management Program Inspections under Clean Air Act
Section 112(r) www.epa.gov/oem/docs/chem/audit_gd.pdf
Civil Penalty Policies http://cfpub.epa.gov/compliance/resources/policies/civil/penalty/
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SECTION IV: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS
ENVIRONMENTAL PROBLEMS FROM WATER POLLUTION
A. Clean Water Act (CWA)
OECA addresses water pollution problems resulting from noncompliance with our nation's
environmental statutes and regulations, including the following CWA programs:
National Pollutant Discharge Elimination System (NPDES) Program (including general
and individual permits from sources such as municipal and industrial wastewater
treatment facilities and their collection systems, concentrated animal feeding operations
(CAFOs), industrial storm water, and vessels).
Pretreatment Program
Biosolids/ Sludge Program
CWA Section 404 (Wetlands) Program
CWA Section 311 (Oil Pollution Act, including the Spill Prevention Control and
Countermeasures (SPCC) Program)
1. Clean Water Act Action Plan
OECA together with EPA Regions, States and the Office of Water continue to implement the
CWA Action Plan ("the Action Plan") issued in October 2009. Pursuant to the Action Decision
Document, scheduled for issuance in the 3rd quarter of FY11, EPA is making four fundamental
changes to revamp the NPDES permitting, compliance and enforcement program to better
address today's serious water quality problems:
1. Replace existing paper reporting with electronic reporting, automated compliance
evaluations and improved transparency.
2. Create a new paradigm for regulations and permits to compel compliance via public
accountability, self-monitoring, electronic reporting and other methods.
3. Address this decade's serious water pollution problems by re-tooling key NPDES
permitting and enforcement practices, and continue to vigorously enforce the Clean Water
Act.
4. Conduct comprehensive and coordinated permitting, compliance, and enforcement
programs to improve state and EPA performance in improving water quality.
These elements are consistent with the Assistant Administrator's goals for the compliance and
enforcement program, listed on pages 6 and 7 of this Guidance.
States and regions should participate in workgroups tasked with designing these changes as well
as use/implement the new tools, pilot projects, policies and regulations as appropriate. A list of
the workgroups and pilot projects along with the lead OECA contacts for these efforts will be
available in the third quarter of FY11 on the CWA Action Plan OTIS site. Regions should notify
OECA leads of their interest in working on these projects. For FY12, Regions should
participate in the following CWA Plan efforts already under development:
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Where appropriate, and in accordance with any subsequent guidance, enforcement actions
should require electronic reporting, as appropriate, for all data required by the enforcement
actions.
Where appropriate, and in accordance with any subsequent guidance, compliance assistance,
monitoring and enforcement personnel should provide relevant feedback to permitting offices
regarding permit prioritization and modifications to consider when permit is renewed.
Where the regions have direct implementation responsibilities, utilize multi-sector general
permit (MSGP) violation and benchmark data to support monitoring and enforcement. The
Water Enforcement Division is working with the Office of Water to obtain these data and
make them available to regions in a usable format. The data will also be used to inform
decisions on development of model documents such as 308 information requests,
administrative orders, and administrative penalty orders.
Regions should investigate the Clean Water Act (CWA) compliance status of surface mining
facilities within each Region, including mountaintop removal mining operations. Regions
should evaluate the compliance status of such facilities with respect to both NPDES
permitting requirements as well as 404 permitting requirements. If CWA violations are
identified, enforcement action should be taken where appropriate.
Actively participate in CWA Action Plan pilots (as developed in FY2011 for implementation
in FY2012) to address effluent violations reported on DMRs using new strategies and tools,
such as expedited administrative enforcement actions and electronic compliance assistance.
Consider pilots or innovate approaches to deal with more routine, paperwork violations.
Actively market and implement the use of NetDMR or other e-DMR tools by permittees for
the electronic transfer of Discharge Monitoring Reports (DMR) to ICIS-NPDES, supported
by use of the National Environmental Information Exchange Network (Exchange Network),
by all of their NPDES permitted facilities.
Regions should support additional CWA Action Plan commitments as further developed.
Regions should broaden the scope of targeting, monitoring and enforcement beyond
traditional NPDES majors, utilizing new targeting tools as developed. To assist in these
efforts, OECA and OW recently released a DMR Pollutant Loadings Tool (currently in Beta
version for user testing) to help the Regions determine who is discharging and where, along
with what pollutants are being discharged and how much. This tool includes minor facilities,
and can be found at www.epa-otis.gov/echo/dmr loading tool.html.
2. High Priority Performance Goal
For FY 2012, pursuant to direction from the Office of Management and Budget, each federal
department and agency must develop and report on a set of High Priority Performance Goals
(HPPGs) that will measure performance for a limited set of high priority activities. EPA has
developed a HPPG that measures EPA's actions to improve water quality through
implementation of the Clean Water Act Action Plan. For FY 2012, OECA has the following
HPPG:
Increase pollutant-reducing enforcement actions in waters that don't meet water quality
standards, from an FY2009 baseline of 32% to a target of 37% in FY2012.
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This HPPG aligns with the Clean Water Act Action Plan goal of targeting enforcement to serious
water pollution problems. The HPPG is not based on expected increases in enforcement actions,
but rather a greater emphasis on taking enforcement actions against facilities that discharge
pollutants into waters not achieving water quality standards for those standards. The
enforcement actions are concluded judicial and administrative enforcement cases that result in a
reduction in the relevant pollutants. The HPPG is limited to EPA actions only because at present
OECA does not have the necessary information to report on state enforcement actions. For
purposes of the HPPG, we define waters as not meeting water quality standards as broader than
the impaired waters list. See the November 11, 2010 "Guidance on Implementing FY2011 High
Priority Performance Goals" for more details on how to target and report for this measure.
OECA will continue to improve GIS-based targeting tools to link relevant water quality
information to facility location, discharges and compliance information as part of developing the
next generation of analytical tools under the Action Plan.
Continuing in FY 2012, OECA will be tracking the performance of Regions to target
enforcement actions on facilities discharging into waters not achieving water quality standards.
COMMITMENT CWA 10: Regions should focus their CWA enforcement work towards
meeting the national target of 37% for concluding federal judicial and administrative
enforcement actions resulting in a reduction of pollutants that pertain to facilities discharging
into waters that do not achieve water quality standards. The Regions should report their data per
the November 2010 guidance issued by OECA, and any subsequent updates issued for FY2012.
3. Implement National Enforcement Initiatives
The relevant FY 2011 - 2013 national enforcement initiatives for CWA programs are:
Keeping Raw Sewage and Contaminated Stormwater Out of Our Nation's Waters: EPA
will continue its enforcement focus on reducing discharges of raw sewage and contaminated
Stormwater into our nation's rivers, streams and lakes. Older urban areas in particular have aging
sewer systems that are not designed to handle heavy rainfall and snowfall, in addition to growing
urban populations and industrial discharges. As a result, untreated sewage too frequently
overflows from sewers into waterways, or backs up into city streets or basements of homes. Raw
sewage contains pathogens that threaten public health, leading to beach closures and public
advisories against fishing and swimming. This problem particularly affects older urban areas,
where minority and low income communities are often concentrated. In addition, Stormwater
runoff from urban streets and construction sites carries sediment, metal, oil and grease, acid,
chemicals, toxic materials and industrial waste into surface waters. Many cities use rivers as the
source of their drinking water, and contaminants in the water increase the difficulty and expense
of treating the water for drinking water use. The Clean Water Act requires municipalities to treat
sewage before it is discharged and to control contaminated Stormwater discharges, but many
municipalities are not complying with these requirements. EPA's enforcement efforts in recent
years have resulted in agreements by many cities to remedy these problems, but the problem
remains in many other cities. This National Enforcement Initiative will focus on reducing
discharges from combined sewer overflows (CSOs), sanitary sewer overflows (SSOs), and
FY2012 OECA NPM Guidance Page 27
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municipal separate storm sewer systems (MS4s) in FY2011-13, by obtaining cities'
commitments to implement timely, affordable solutions to these problems, including increased
use of green infrastructure and other innovative approaches. EPA is committed to working with
communities to incorporate green infrastructure, such as green roofs, rain gardens, and
permeable pavement, into permitting and enforcement actions to reduce storm water pollution
and sewer overflows. Regions should consider and promote the opportunity to utilize green
infrastructure controls in municipal enforcement actions. Green infrastructure approaches have
the potential to help reduce and/or eliminate CSOs and SSOs in a cost effective manner while
providing a variety of environmental and community benefits, including improved water and air
quality, increased energy efficiency, green spaces and economic development. For these
reasons, EPA is committed to the incorporation of green infrastructure projects into municipal
settlements where appropriate. Information on green infrastructure projects can be found at:
http://cfpub.epa. gov/npdes/home. cfm?program_id=298.
Preventing Animal Waste from Contaminating Surface and Ground Waters: Concentrated
Animal Feeding Operations (CAFOs) are defined as agricultural operations where animals live in
a confined environment (see 40 CFR Section 123). CAFOs can contain large numbers of
animals, feed, manure, dead animals and production operations on a small land area. The animals
generate a large amount of manure, which typically is held in lagoons or spread on nearby fields.
If not properly controlled, manure can overflow from lagoons or run off from the fields into
nearby surface waters or seep into ground water, carrying disease-causing pathogens, nutrients,
or other contaminants into the water. This contaminates both surface waters and ground waters
that may be used as drinking water sources and harms fish and other aquatic species in surface
waters.
Several studies have found high concentrations of CAFOs in areas with low income and minority
populations. This is typical in many rural areas of the country where livestock facilities are
located. Children in these areas may be particularly susceptible to potential adverse health
effects through exposure to contaminated surface waters or drinking water from contaminated
ground water sources. The Clean Water Act prohibits the discharge of these pollutants into
surface waters, and EPA's regulations require larger CAFOs to have permits (which impose
control requirements) if the waste produced by animals on the farm will run off into surface
waters. However, many CAFOs are not complying with these requirements, so EPA will
continue to strengthen its enforcement focus on these facilities, and those in priority watersheds.
For FY2011-13, OECA will focus primarily on existing large and medium CAFOs identified as
discharging without a permit. In addition, each Region will consider a variety of factors to
prioritize CAFO - related activities (i.e., compliance assistance, monitoring and enforcement).
These factors include identifying watersheds where CAFOs are negatively affecting water
quality, proximity to vulnerable communities, strengths and challenges of state CAFO programs,
as well as other considerations.
Assuring Energy Extraction Sector Compliance with Environmental Laws: As the nation
expands its search for new forms and sources of energy, there is an urgent need to assure that we
develop "clean energy" sources that protect our air, water and land. Some energy extraction
activities, such as new techniques for gas extraction, pose a risk of pollution of air, surface
waters and ground waters if not properly controlled. For example, an unprecedented acceleration
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of natural gas leasing and development has led to a significant rise in the level of air pollution
throughout the intermountain West. Drilling and fracking activities have led to concerns about
ground water pollution and the safety of drinking water supplies in various parts of the country.
To address these emerging problems, OECA's energy extraction initiative will focus on efforts to
assure that natural gas extraction activities are complying with federal requirements to prevent
pollution of our air, water and land. This initiative will be undertaken in particular areas of the
country where natural gas extraction activities are concentrated, and the focus and nature of our
enforcement activities will vary with the type of activity and pollution problem presented.
Implementation plans are being developed for the Municipal, CAFO, and Energy Extraction
Initiatives that will include final goals and measures, and guidance on implementation. Region-
specific commitments for activities to support the goals and measures will be negotiated through
the ACS process.
4. Link with Top Office of Water Priorities
OECA addresses top Office of Water priorities for the CWA in the following ways:
Restoring and Protecting Urban Waters: As part of aggressively going after pollution that
matters to communities, OECA's enforcement and compliance will be particularly focused
on protecting communities by getting raw sewage out of the water, cutting pollution from
animal waste, and reducing polluted stormwater runoff.
Strengthening Protections for Our Waters: OECA is improving protection of water through
the Clean Water Act Action Plan
http://www.epa.gov/compliance/civil/cwa/cwaenfplan.html).
Chesapeake Bay: Regions 2, 3, 4, and 5 should refer to the Chesapeake Bay Compliance and
Enforcement Strategy implementation plans (available upon request) for details about
expectations and commitments for storm water, waste water, air and CAFOs.
Implementation plans include goals and measures with targets for accomplishing activities to
support each, e.g., 3 MS4 audits per year. (Note: CAFO commitments are not yet
finalized.) The Strategy and other relevant information related to compliance and
enforcement is posted at
http://www.epa.gov/compliance/civil/initiatives/chesapeakebay.html)
5. Aggressively Go After Pollution Problems That Make a Difference in Communities
Communities across the country depend on clean water as a source of drinking water, a habitat to
support healthy ecosystems and as a resource for recreation and fishing. They expect protection
from exposure to water contaminated by raw sewage, animal waste and pollutants in urban storm
water run-off
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Direct exposure to raw sewage and associated high levels of disease-causing organisms can be a
particular problem for communities located in older urban areas where the aging municipal
wastewater infrastructure may be failing or unable to handle the demands of a growing urban
population. When pipes break, equipment fails or the system exceeds capacity, untreated
wastewater flows into waterways, homes and city streets, most significantly exposing the
community to pathogens. Urban water bodies can also be assaulted by large volumes of
uncontrolled polluted storm water from streets, parking lots, and commercial and industrial
businesses. Many of these older urban areas include minority and low income communities.
Exposure to animal waste from concentrated animal feeding operations may particularly affect
low income and minority populations in rural areas. Water bodies polluted by the waste can
cause human illness after swimming or wading and result in contaminated fish and shellfish.
This is a particular problem with respect to subsistence fishing, which is most frequent in
minority and low income populations.
OEC A, together with the Office of Water and state water control agencies will work to identify
at-risk waters and use their appropriate regulatory tools, including setting strong water quality
standards, issuing protective and enforceable NPDES permits and addressing serious violations
through effective enforcement to ensure water quality protection and restoration.
A. CWA NPDES Program
Regions in non-authorized States and Indian country, and authorized States and Tribes, should:
Target to identify serious sources of pollution and serious violations. Use the new tools
developed pursuant to the CWA Plan in FY2011 such as available ambient monitoring
data, pollutant loadings, and GIS, to target the most significant sources of pollutants on
those water bodies and watersheds including those that are not meeting water quality
standards as broadly defined in the HPPG Guidance.
OEC A has developed the Inspection Targeting Model for the Clean Water Act (currently
in Beta version for user testing) that includes "Is the facility or outfall within 15 Miles
Upstream of a Drinking Water Intake?" as part of its indexing. This model can be
accessed through OTIS (www.epa-otis.gov/otis/itm) and OECA is looking for feedback
on this model. Develop annual compliance monitoring plans that take advantage of the
flexibility available in the National Pollutant Discharge Elimination System Compliance
Monitoring Strategy for the Core Program and Wet Weather Sources (issued October 17,
2007), along with additional approaches identified in the CWA Action Plan, to target
inspections aimed at identifying and addressing serious water quality problems where
NPDES compliance and enforcement tools will be effective in addressing the pollution
problem.
Evaluate all violations to determine seriousness and determine an appropriate response.
Facilities in significant noncompliance (SNC) should be acted on, along with sources
with serious effluent limit violations, unpermitted discharges, systemic reporting
problems or violations at facilities with potential to seriously impact to water quality.
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Initiate and complete civil enforcement actions, where appropriate to address serious
violations contributing to a community's water quality problems. This includes judicial
and administrative actions. Ensure compliance with consent decrees and administrative
orders. Implement targeted "real time" (quick response) enforcement activities to address
violations impacting communities' waters, such as violations at concentrated animal
feeding operations. OECA will provide additional training and guidance on this
approach in FY11. Utilize assistance, incentives, monitoring and enforcement tools to
address serious noncompliance problems causing water quality problems in targeted
communities and watersheds.
In addition, Regions should:
Implement CWA specific geographic compliance and enforcement strategies, as
appropriate for their Region, including CWA Action Plan pilots, the Chesapeake Bay
Compliance and Enforcement Strategy, and other region-specific geographic initiatives.
Routinely review all DMRs and non-compliance reports received for compliance with
permit requirements where the Region directly implements the program. (Note that
Regions may accomplish this review through a routine screen of the PCS or ICIS-NPDES
data and reviewing the DMRs themselves as necessary.)
Where the Region has direct implementation responsibilities, they should inspect and
audit pretreatment POTWs and Industrial Users (lUs) to evaluate the effectiveness of the
regulatory authorities pretreatment program, either in conjunction with other compliance
inspections at major and minor POTWs such as compliance evaluations (CEIs) or
separately.
Where the Region has direct implementation responsibilities, they should inspect
biosolids/sludge facilities to evaluate the permittee's compliance with sludge monitoring,
record keeping and reporting, treatment operations, and sampling and laboratory quality
assurance, either in conjunction with other compliance inspections at major and minor
POTWs such as compliance evaluations (CEIs) or separately.
Use all available data to benchmark and monitor state performance using data from
federal and state data systems, permitting and enforcement performance reviews, and
other audit or evaluation reports. These include State Review Framework reviews, Office
of Water Permit Quality Reviews, regular EPA/State meetings to review performance,
state data not entered into national databases and GAO and/or IG reviews of state
performance. In FY2011, EPA developed an integrated and streamlined NPDES
enforcement and permitting oversight review process, issued guidance and provided
training to EPA Regions. In FY12, EPA Regions will pilot integrated NPDES
enforcement and permitting oversight reviews.
Where States have exhibited a widespread and long-standing problem with significant
aspects of their permitting or enforcement programs, Regions should object to permits or
take direct enforcement actions in those states in accordance with EPA's June 22, 2010
Memorandum titled, "Interim Guidance to Strengthen Performance in the NPDES
Program" signed by Cynthia Giles, Assistant Administrator for OECA and Peter Silva,
Assistant Administrator for Water. Regions should focus oversight resources on the
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most pressing performance problems in States which had been identified through
permitting and enforcement reviews. Regions and States must work together to
demonstrably improve state performance. Guidance will be made available under the
Clean Water Act Action Plan to further clarify expectations.
Coordinate, as appropriate, with the Coast Guard and other federal agencies which have
significant roles in addressing spills, and follow all related Memoranda of Agreement
including the MOU for the Vessels General Permit.
Continue implementing the Federal Facility Integrated Strategy on Stormwater.
Encourage States that are currently using the NPDES Permit Compliance System (PCS)
to prepare to migrate to the modernized data system, ICIS-NPDES. The batch data flow
capability from States to ICIS-NPDES through EPA's National Environmental
Information Exchange Network is currently under development and is scheduled to be
implemented in three distinct releases. The first release, completed February 2011, will
provide functionality for the transmittal of Permit and Facility information. The second
release, scheduled for January 2012, will provide functionality for the transmittal of
Inspection information. The final release, scheduled for March of 2013, will provide
functionality for the transmittal of remaining NPDES data families to include
enforcement actions, single event violations, and program reports. Regions should
support their States as they move to ICIS-NPDES.
Regions should seek injunctive relief to correct violations and protect watersheds,
including implementing green infrastructure and innovative technologies, where
appropriate.
COMMITMENT CWA07: By December 31, 2011, provide a specific NPDES Compliance
Monitoring Strategy (CMS) plan for each State in the Region. The plan should provide universe
information for the CMS categories; sub-categories covered by the CMS and combined EPA and
State expected accomplishments for each category and subcategory. The plan should identify
trade-offs made among the categories utilizing the flexibility designed into the CMS policy to
target the most significant sources with potential to impact water quality. At end of year provide
for each State a numerical report on EPA and state inspection plan outputs, by category and
subcategory. To increase the transparency of NPDES inspection data, OECA will work with
Regions and State associations to develop formats for releasing inspection data on CMS
implementation performance on a state-by-state basis.
B. CWA Section 404 - Discharge of Dredge and Fill material
Regions should:
Coordinate, as appropriate, with other federal agencies (e.g., U.S. Army Corps of
Engineers, Natural Resources Conservation Service (NRCS), Fish and Wildlife Service,
etc.) which have significant roles in wetlands protection through the use of memoranda of
understanding and memoranda of agreement or other appropriate mechanisms.
Meet with Corps Districts on an annual basis to establish regional priorities and
communicate priorities to OECA;
Review field level agreements with Corps Districts, and revise to make them consistent
with Section 404 Enforcement Strategy, as appropriate;
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Regions should utilize the Office of Water's DARTER (Data on Aquatic Resources
Tracking for Effective Regulation) system as well ICIS (Integrated Compliance
Information System) in their targeting efforts to identify potential repeat and flagrant
violators (ICIS continues to be the data base of record for tracking EPA information on
404 enforcement actions);
Develop methods to effectively leverage other program resources to more systematically
identify potential serious Section 404 violations and take appropriate enforcement
response to address these violations. Share effective techniques with OECA for use in
developing the national wetlands enforcement strategy;
Utilize existing Regional cross training opportunities as well as opportunities identified
by HQ to cross-train inspectors and to train other federal and state agencies and
stakeholders to identify CWA 404 violations;
The Section 404 Enforcement Strategy will be piloted during 2011 - 2012, and the
Regions are expected to work with OECA in implementing the strategy.
C. CWA Section 311-Oil Pollution Act
The activities described below are intended to be conducted by enforcement staff or
contractors. OECA has contract resources available to support such work
Regions should:
Participate in multi-regional judicial enforcement cases to address spills from inter-state
pipelines and others, such as production facilities, on a company-wide basis. Cases will
include company-wide injunctive relief requirements to prevent future spill violations at
all facilities of the owner or operator.
Participate in multi-regional judicial enforcement cases to address federal response
planning (FRP) violations at facilities owned or operated by the same company. Cases
will include company-wide injunctive relief requirements to improve facility response
planning and implementation at all facilities of the owner or operator.
Investigate and develop informal, administrative and judicial enforcement actions to
address noncompliance with EPA product schedule requirements for use of dispersants
and other substances. Investigate, target and develop informal, administrative and
judicial enforcement actions to address spill prevention, and facility response planning
violations at facilities subject to EPA regulations, including offshore platforms within
EPA jurisdiction. Also investigate, target, and develop informal, administrative and
judicial enforcement actions to address discharge violations (spills) where ever the
violation occurs, whether or not the spill occurred at a facility subject to EPA's spill
prevention or facility response planning regulations.
Whenever needed in the context of an enforcement action or enforcement targeting effort,
conduct inspections and enforcement investigations as needed to confirm violations or
develop enforcement cases. These activities are intended to be conducted by
enforcement staff or contractors, when needed for enforcement targeting or case
development.
Conduct enforcement investigations to identify noncompliance, target appropriately for
enforcement response, and build cases for enforcement actions. Enforcement
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investigations could include use of CWA Section 308 and/or 311(m) information
requests, independent audits, interviews, review of inspection reports, coordination with
state and other federal agencies, use of public tips and complaints, review of public
databases, or other investigative means. Whenever spill or regulatory enforcement is
pursued at facilities subject to EPA regulations, the case development staff should
evaluate whether the facility is in compliance with allspill prevention and facility
response planning requirements and should include claims in the enforcement case to
address all noncompliance in these areas.
As part of enforcement targeting work, review spill notification reports to the National
Response Center, pipeline spill reports to the Pipeline and Hazardous Materials Safety
Administration, spills reported to states and other available sources to identify spill
violations. Issue CWA 308 information requests to confirm violations and identify
causes of the spills. Take appropriate enforcement action to address spills of oil and
hazardous substances that have occurred, to include penalties and injunctive relief to
prevent future violations from similar causes across all facilities of the same owner or
operator.
Participate in OECA-led coordination and strategy meetings, as appropriate.
6. Reset Our Relationships with States
Every Region and State, working together, should conduct a CWA annual planning process that
brings the different components of the regional and state NPDES program (water quality
standards and assessment, permitting and enforcement) all to the table together, identifies and
discusses national, regional, and state priorities versus available resources at both the state and
federal levels, and results in collaborative annual work plans that use all available mechanisms to
get work done, such as federal and state work-sharing, innovative approaches to monitoring
facilities or addressing violations, etc.
Regions should:
Hold annual planning meetings with each State to develop collaborative annual work
plans. Submit summary report to headquarters by October 31, 2011.
Convene routine and regular meetings between the Region and State to discuss progress
towards meeting annual permitting and enforcement commitments, and how the State has
been performing overall in the NPDES program.
Where States are not meeting performance expectations, Regions should take
enforcement actions to address serious violations. Regions should focus oversight
resources to the most pressing performance problems in States and should work to
demonstrably improve state performance through these actions. Regions need to take
action when necessary to communicate what things need attention to achieve goals of the
federal environmental laws and ensure a level playing field between States.
Conduct a sufficient number of oversight NPDES inspections to ensure the integrity and
quality of each State or Tribe with primacy compliance monitoring programs. The
Regions have flexibility to determine the appropriate number of oversight inspections
needed to ensure proper state inspection conduct and documentation. Oversight
inspections are not "joint" inspections. Oversight inspections can be conducted by
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accompanying state inspectors during inspections, or conducting a separate inspection at
the same facility at a later date to verify the same findings.
Implement the State Review Framework (SRF) for the NPDES program in conjunction
with permit quality reviews and assure implementation associated with corrective actions
identified in the SRF reports.
Consider the following information when conducting state program oversight:
o number of SNCs identified (and percent of universe), especially those related to
effluent exceedance or illegal discharges by state and by region
o number (and percent) addressed in a timely and appropriate manner
o results of SRF and permit quality reviews and progress in correcting identified
issues.
Consult with Tribes on the central role that enforcement and compliance plays in EPA's
direct implementation program and oversight of approved tribal programs.
COMMITMENT CWA09: Regions should submit summaries of the collaborative EPA/State
annual work planning process addressing NPDES permitting, compliance monitoring, and
enforcement activities, including work-sharing, to the Office of Compliance and the Office of
Wastewater Management by October 31, 2011 for FY 2012 activities.
7. Improve Transparency
Data regarding state assessments, priorities and performance under the CWA should be
made public by the Regions and Headquarters, where possible, on a regular basis in a
manner easily understood and used by the public.
If data systems are not able to support reporting at end-of-year FY 2011, the Regions
should manually report using instructions specified in the multi-program fiscal year
reporting guidance memorandum.
Regions should work with the States and Tribes to verify that their compliance and
enforcement data is input into national databases.
Compliance monitoring activities conducted pursuant to the goals in CMS and the state-
specific plans should be reported into the appropriate national information system, either
PCS or ICIS-NPDES, in accordance with documents which establish data requirements
and reporting timeframes for those systems. States must ensure that all required
compliance and enforcement data is input or transmitted to the national databases. EPA
encourages States to expand their use of the national databases to include compliance and
enforcement data that pertains to the entire NPDES universe
Regions should review reporting practices to ensure that oil and hazardous substance
spills are timely and accurately reported to the National Response Center (NRC)
Regions should make information available to communities, including Native American
and Alaskan Natives, who lack access to the internet.
8. Relevant Policies and Guidances
Additional information about OECA's Clean Water Act programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/cwa/index.html
http://www.epa.gov/compliance/civil/cwa/index.html
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B. Safe Drinking Water Act (SDWA)
OECA addresses drinking water pollution problems through the following SDWA programs:
Public Water System Supervision (PWSS) Program
Underground Injection Control (UIC) Program
EPA's focus on regulated drinking water systems, including those in Indian country, protects the
public from the potential acute and chronic health effects of drinking water that fails to comply
with the SDWA. The Enforcement Targeting Tool (ETT) identifies those public water systems
(PWSs) that have the most serious, most numerous, and longest-lasting unresolved drinking
water violations. The Enforcement Response Policy (ERP) establishes EPA's expectations of
how primacy agencies are to address drinking water violations and return violating PWSs to
compliance.
The ETT assigns to each drinking water violation a numerical point value weighted for its
severity, and applies a formula that generates a total score for each PWS with unresolved
violations. Because violations of health-based standards and major violations of monitoring and
reporting requirements for acute contaminants present the most serious risks to the public's
health, violations of these types are assigned the highest point values. Major monitoring and
reporting violations related to chronic contaminants, minor monitoring and reporting violations,
and public notification violations are assigned lower point values. The higher a PWS's total ETT
score, the more serious is its overall noncompliance.
The ERP provides that all drinking water violations at PWSs are to be resolved and that PWSs
are returned to compliance. Additionally, the ERP directs that if a PWS reaches an ETT score
of 11 or higher before its violations are resolved, that PWS will be considered a priority system
that must either return to compliance or receive formal enforcement action within six months of
having reached a score of 11. It is OECA's expectation that primacy agencies will
simultaneously be working to reduce their backlog of systems that have already been at a score
of 11 or higher for more than 6 months. As a longer term goal, primacy agencies are encouraged
to address violations at noncomplying PWSs before they become priority systems. A quick
response to SDWA violations decreases the risks to public health and allows primacy agencies
more flexibility as they work with PWSs to achieve sustained compliance. By focusing
resources on PWSs in this way, the ERP helps ensure those PWSs return to compliance in a
timely manner.
1. Link with Top Office of Water Priorities
OECA addresses top Office of Water priorities for the SDWA in the following ways:
Safeguarding Public Health: As part of aggressively going after pollution that matters to
communities, OECA will use all enforcement and compliance tools to assure public
water systems deliver safe drinking water, with continued focus on drinking water in
schools and in Indian country.
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2. Aggressively Go After Pollution Problems That Make a Difference in Communities
The ETT and ERP apply equally to EPA direct implementation, including in Indian country, and
implementation by states, territories, and tribes with primacy. EPA's goal is to ensure that the
drinking water delivered in Indian country is as safe as the drinking water delivered to the rest of
the American public.
The ETT's scoring formula focuses enforcement resources on those systems with health-based
violations, those with major monitoring and reporting violations, and those that show a history of
violations across multiple rules. Its system-based methodology is intended to ensure national
consistency and the integrity of the Public Water System Supervision national enforcement
program while providing increased protection for the public.
Regions, states, territories, and tribes with primacy will work to resolve all SDWA violations.
Because ETT scores identify the PWSs with serious noncompliance problems, primacy agencies
can establish priorities allowing them to address systems with the worst violations first. The
timely and appropriate response guidelines in the ERP ensure timely action is taken to return
serious violators to compliance.
In accordance with the ERP, all PWSs that reach a score of 11 or higher (priority systems) are to
be addressed with a formal enforcement action or returned to compliance within six months of
the quarterly ETT report on which the system first is reported as having a score of 11 or higher.
OECA headquarters will track primacy agency performance in meeting the timely and
appropriate provisions of the ERP.
COMMITMENT SDWA02:
During FY 2012, the primacy agency must address with a formal enforcement action or
return to compliance the number of priority systems equal to the number of its PWSs that
have a score of 11 or higher on the July 2011 ETT report3.
State, territory and tribal breakouts should be indicated in the comment field of the
Annual Commitment System.
3. Reset Our Relationships with States
Regions are responsible for working with states, territories, and tribes with primacy in an
oversight capacity to ensure that the ETT and ERP are implemented as intended. While OECA
and the Regions will discuss progress returning systems to compliance, identify those priority
systems for which return to compliance is impracticable, and oversee performance overall in
implementation of the program, the Regions will hold more in depth discussions with their states,
3 A primacy agency's success at addressing violations will be tracked by means of the quarterly ETT reports.
Numerical targets may be adjusted at mid-year. While it remains the ERP's goal that all of a priority system's
violations will be returned to compliance, a primacy agency has met its commitment under the 2012 SDWA ACS
with respect to a priority system if the score for that system has been brought below, and remains below, eleven.
FY2012 OECA NPM Guidance Page 37
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territories, and tribes that include, but are not limited, to progress in returning systems to
compliance, monitoring compliance progress on orders, systems addressed, and overall
performance in implementing the program. These meetings may be held in person or through
conference calls or other venues, as appropriate. EPA strongly suggests a minimum of quarterly
communication as a best practice for ensuring progress in meeting goals.
Where states are not meeting performance expectations established by this commitment, regions
should take action to ensure the highest priority systems are addressed. Regions should focus
oversight resources on the most pressing performance problems in states/territories and should
work to improve performance through these actions.
OECA will perform this oversight function with respect to direct implementation programs.
OECA will engage with regions on a regular basis to ensure that regions are directly
implementing the program in Indian country, Wyoming, and the District of Columbia effectively
and applying the ETT and ERP as intended. EPA's direct implementation programs will consult,
as appropriate, with potentially impacted tribal governments when conducting inspections and
addressing noncompliance at tribal and non-tribal PWSs in Indian country.
4. Improve Transparency
OECA headquarters will report on progress in returning systems to compliance in its annual
national compliance report posted on the EPA website at
http://cfpub.epa.gov/compliance/resources/reports/accomplishment/sdwa/
Compliance and enforcement data for all drinking water systems will be made available to the
public through the Enforcement and Compliance History Online website.
5. Relevant Policies and Guidances
Additional information about OECA's SDWA and tribal programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/sdwa/index.html
http://www.epa.gov/compliance/civil/sdwa/index.html
http://www.epa.gov/compliance/resources/policies/civil/sdwa/drinking_water_erp_2009.
p_df
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SECTION V: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS
ENVIRONMENTAL PROBLEMS FROM WASTE, TOXICS, AND PESTICIDES
POLLUTION
A. Resource Conservation and Recovery Act (RCRA)
OECA's RCRA program addresses the management of solid and hazardous waste and
underground storage tanks (UST). For more information on the management of hazardous waste
under RCRA Subtitle C, readers are urged to review the RCRA Compliance Monitoring Strategy
(CMS) which provides detailed information about goals and measures, policies which allow
flexibility from OECA's expectations, program oversight, and other aspects of the RCRA
compliance monitoring program.
1. Statutory and Regulatory Requirements
RCRA dictates minimum inspection frequencies for treatment, storage, and disposal facilities
(TSDF) - annually for TSDFs operated by state/local governments, and biennially for non-
governmental TSDFs. RCRA01 and RCRAOl.s apply to TSDFs owned or operated by non-
governmental entities, and to TSDFs owned but not operated by state/local/tribal governments.
RCRA03 applies to TSDFs operated by state/local/tribal governments. The inspections
performed under these RCRA commitments should be Compliance Evaluation Inspections
(CEIs).
COMMITMENT RCRA01: Project by State, and Indian country where applicable, the number
of operating non-governmental TSDFs, to be inspected by the Region during the year4. Regions
must commit to inspect at least two (2) TSDFs in each State or Indian country unless OECA
approves a deviation from this requirement. For example, deviations are given for states with
small universes where it might not make sense for a Region to inspect two TSDFs per year.
Financial responsibility is an important component of the RCRA core program and should be
included as part of the inspection of each TSDF (although the financial responsibility reviews do
not have to occur at the same time nor be conducted by the same people who conduct the field
inspections).
COMMITMENT RCRAOl.s: Project by State the number of operating TSDFs to be inspected
by the State during the year.
The RCRA CMS establishes minimum annual inspection expectations for TSDFs: The
inspections for RCRA01 and RCRAOl.s should be CEIs. Only one inspection per facility
counts towards this coverage measure.
COMMITMENT RCRA03: Inspect each operating TSDF operated by states, local, or Tribal
governments.
4 Currently there is only one TSD in Indian country.
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COMMITMENT RCRA04: Project by State and Indian country the number of financial
assurance mechanisms to be reviewed by the Region during the year. Regions must commit to
review financial test and/or corporate guarantee submissions for compliance with the closure and
post-closure regulations at a number of facilities at least equal to the Region's commitment under
RCRA01. As an alternative, Regions may choose to conduct formal financial record reviews for
facilities that did not have a financial assurance review during the FY 2005-FY 2010 as part of
the national enforcement initiative. The financial test/corporate guarantee compliance
evaluations or financial record reviews may occur at the same facilities being inspected under
RCRA01 or at different TSDFs.
The financial test/corporate guarantee compliance evaluations should take place within 90 days
after the facility's annual submission is received.
Regions should ensure continued review of financial test/corporate guarantee
submissions since they present the greatest risk and are the most commonly used
instruments.
Regions are expected to focus on reviewing the universe of TSDFs not formally
evaluated during the national priority, and on conducting in-depth reviews of financial
test/corporate guarantee submissions.
Regions are to coordinate with States to conduct these financial assurance reviews.
2. Implement National Enforcement Initiatives
The relevant FY 2011 - 2013 national enforcement initiative for RCRA programs is:
Reducing Pollution from Mineral Processing Operations: Mining and mineral processing
facilities generate more toxic and hazardous waste than any other industrial sector, based on
EPA's Toxic Release Inventory. Many of these facilities have impacted surrounding
communities and continue to pose high risk to human health and the environment. For example,
95 mining and mineral processing sites are on the Superfund National Priorities List and more
sites are being added every year, including operating facilities. EPA has spent over $2.4 billion
to address the human health and environmental threats to communities, such as exposure to
asbestos and lead poisoning in children, as a result of mining and mineral processing. In some
cases, EPA had to relocate families because of these threats, especially those to children in low
income communities. EPA has inspected 65 mining and mineral processing sites that pose
significant risk to communities and found many to be in serious non-compliance with hazardous
waste and other environmental laws. Contamination of groundwater and potable water has
occurred at many sites, sometimes requiring alternative drinking water supplies or removal of
lead-contaminated soil from residential yards. In other cases, toxic spills into waterways from
mining and mineral processing caused massive fish kills and impacted the livelihood of low
income communities. Some workers at mining and mineral processing facilities have been
exposed to spills and mismanagement of toxic and hazardous waste. EPA will continue its
FY2012 OECA NPM Guidance Page 40
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enforcement initiative to bring these facilities into compliance with the law and protect the
environment and nearby communities.
OECA has not finalized the goals and annual commitments for its national enforcement
initiatives, but it is expected there will be approximately 13 mineral processing inspections
required for 2012 nationally.
3. Link with Top OSWER Priorities
OECA addresses top OSWER priorities for RCRA in the following ways:
Recycling, Waste Minimization and Energy Recovery: OECA maintains an overall
enforcement presence in RCRA that supports OSWER in their work.
Emergency Preparedness, Implementing the EPAct Response and Homeland Security:
OECA maintains an overall enforcement presence in RCRA that supports OSWER in
their work.
Preventing Underground Storage Tank Releases: The RCRA Subtitle I enforcement
program is focused on ensuring facilities comply with the UST regulations. These
regulations require facilities to monitor UST systems to prevent leaks. OECA's NPM
guidance fully supports OSWER's goal of preventing underground storage tank releases
through the activities identified in section 4(b).
Cleaning up Underground Storage Tank Releases: Regions should monitor for
compliance with UST regulations. When leaks are found, Regions should assure leaks
are addressed as described in the UST Section 4(b) program.
4. Aggressively Go After Pollution Problems That Make a Difference in Communities
a. RCRA Program
Regions and States should inspect pollution problems that matter to communities, and develop
enforcement cases that produce significant environmental benefits. Regions, in their oversight
and direct implementation roles, and authorized States are expected to follow the guidance in the
RCRA CMS. To enable States to address environmental problems of concern to communities,
States may utilize flexibility in the RCRA CMS to deviate from their large quantity generator
(LQG) requirements. RCRA facilities may cause air, surface and groundwater pollution.
Because these facilities are frequently associated with industrial operations, surrounding
communities are often low income and minority.
Issues of emerging environmental concern to EPA and communities are listed here. These focus
areas should be considered a high priority for Regions and States when developing strategies for
targeting compliance assurance work. These should also specifically be discussed between
States and Regions when developing plans for respective activities in the Region. The areas of
concern are:
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Surface Impoundments: EPA, with support from States, continues to focus on problems
associated with illegal disposal of hazardous waste in unlined surface impoundments.
There are thousands of industrial surface impoundments across the country, many of
which adversely impact communities through air, surface water, and/or groundwater
contamination, particularly in the chemical manufacturing and petroleum refining sectors.
Centralized Waste Treatment Facilities: These facilities conduct treatment of industrial
solid waste from third-parties. Through recent inspections, EPA has identified several
such facilities that were grossly mismanaging hazardous wastes, and treating and
discharging these wastes without permits.
Hazardous Waste Recycling Facilities: EPA supports the environmentally beneficial
recycling of hazardous wastes and secondary materials. However, sham recycling and
recycling not done in compliance with RCRA requirements can result in significant
adverse impacts to human health and the environment. This area of concern will include
a focus on zinc fertilizer manufacturing that uses hazardous waste in the production
process.
Coke Manufacturing: There are approximately 20 coke manufacturing facilities in the
United States. EPA has recently inspected and identified multi-media compliance
problems at some of these facilities, including the illegal land disposal of hazardous
waste. This sector produces several listed and characteristic hazardous waste streams that
are excluded from RCRA if recycled without being land disposed. EPA intends to
conduct focused inspections within this sector to ensure compliance.
Waste Analysis Plans at Commercial TSDFs: EPA has conducted sampling at TSDFs to
determine if the facilities' waste analysis plans and treatment of the waste were adequate.
Based on the results of the sampling, concerns have been identified with the treatment
and stabilization techniques and the sampling and analysis of hazardous waste treated to
meet the Land Disposal Restriction (LDR) treatment standards for land disposal.
RCRA Corrective Action: To help achieve the RCRA Corrective Action 2020 Goals,
EPA and authorized States should focus enforcement resources on facilities that have not
made meaningful progress in achieving remedial objectives, and on financially marginal
or bankrupt facilities. Regions should use the prioritization scheme set forth in the
National Enforcement Strategy for Corrective Action when assessing EPA-lead facilities
and prioritizing facilities for corrective action enforcement.
The Regions should:
Provide compliance assistance, conduct compliance monitoring, and pursue enforcement to
ensure that pollution problems that matter to communities are aggressively addressed.
Regions and states are encouraged to support the OC's RCRA inspector training
development effort.
FY2012 OECA NPM Guidance Page 42
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Ensure that state and tribal inspectors who inspect on behalf of EPA are trained and
credentialed per Guidance for Issuing Federal EPA Inspector Credentials to Authorize
Employees of State/Tribal Governments to Conduct Inspections on Behalf of EPA (2004).
COMMITMENT RCRA02: Project by State and Indian country, the number of LQGs,
including those at federal facilities, to be inspected by the Region during the year. Each Region
must commit to inspect at least six (6) LQGs in each State, and 20% of the Region's LQGs
universe in Indian country, unless OECA approves a deviation from this requirement. For
example, deviations are given for states with small universes where it doesn't make sense for a
Region to inspect 6 LQGs per year or 20% of the Region's LQG universe in Indian country. In
the Comment Section, provide the number of federal facility LQG inspections.
COMMITMENT RCRA02.s: Project by State the number of LQGs to be inspected by the
State during the year. At least 20 percent of the LQG universe should be covered by combined
federal and State inspections unless an alternative plan is approved under the RCRA CMS.
The RCRA corrective action financial responsibility measure includes the review of financial test
submissions received by the States within each Region. For those States that are not authorized
for corrective action, the Regions should be reviewing the financial test submissions as part of
EPA's role of implementing and enforcing the corrective action program in unauthorized States.
Regions conducting financial test/corporate guarantee reviews for the RCRA Subtitle C
closure/post-closure regulatory program may also review any corresponding corrective action
submissions as part of the completion of this program measure.
COMMITMENT OSRE04: For 100% of the financial test submissions received each fiscal
year for corrective action with cost estimates over $5 million, determine whether the submission
is in compliance. Where the submission is noncompliant, take appropriate enforcement action to
address noncompliance (e.g., notice of violation). If possible, return facility to compliance by
end of fiscal year.
b. RCRA Underground Storage Tank (UST) Subtitle I Program
A major focus of the RCRA UST program is to maintain an enforcement presence concerning
leak prevention, leak detection, corrective action, closure, and financial responsibility violations.
EPA is committed to ensuring facilities operate underground storage tanks (USTs) in a manner
that is protective of human health and the environment. Agency compliance assurance and
enforcement activities will focus on those facilities posing the greatest risk to human health and
the environment. Regional enforcement efforts should ensure that owner/operators of RCRA
Subtitle I regulated facilities properly prevent and detect releases and take appropriate corrective
action when releases occur.
EPA directly implements the UST program in Indian country in coordination with Tribes and
tribal consortia because RCRA precludes EPA from authorizing tribal UST programs.
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Authorized States have primary responsibility for determining facility compliance, ensuring
adequate inspection coverage of the regulated universe, taking appropriate actions in response to
non-compliance, and playing a vital role in alerting EPA to regulatory implementation problems.
Generally, federal compliance assurance and enforcement will complement and provide
oversight of state activities. Although States with approved programs have primary
responsibility for monitoring compliance and initiating enforcement actions against violators of
the UST requirements, Regions should inspect and initiate federal enforcement cases to
supplement and support state efforts. Federal involvement or support can provide significant
benefits by addressing noncompliance from a national or corporate-wide perspective, facilitating
compliance efforts involving multiple States and/or Regions, and enhancing public awareness in
a broader, more national forum.
Regions should:
Target UST inspections that will produce the greatest environmental and human health
benefits (e.g., leak prevention, leak detection, corrective action, and financial
responsibility). Factors to consider in identifying facilities for inspection under the UST
program include:
Owners and operators of USTs located in Indian country;
Owners and operators with UST facilities in multiple states;
Mid-level distributors with multiple UST facilities;
Problem noncompliers; (i.e.; repeat violators; owners/operators who fail to cooperate
in an effort to return to compliance);
Owners and operators of facilities with USTs that endanger sensitive ecosystems or
sources of drinking water; and
Corporate, government-owned, and federal central fueling facilities.
Regions are expected to take enforcement actions and assess penalties, as appropriate, to
ensure optimum deterrence effect and compliance impact. Regions will consult with the
States on use of the delivery prohibition, when appropriate, to address significant
noncompliance. It is recognized that this tool may not be an option for States and Tribes
that do not have delivery prohibition programs or are not State Authorized Programs.
Focus on developing large complex cases involving noncompliance on a corporate-wide
basis or noncompliance in multi-state operations.
Focus on comprehensively evaluating corporate compliance and fully developing cases
involving noncompliance on a corporate-wide basis or noncompliance that occurs at
facilities located in multiple states.
5. Reset Our Relationships with States
RCRA compliance monitoring is a collaborative effort between OECA, Regions, and authorized
States. Each of these entities performs complementary but distinct roles. OECA provides
national program leadership, and oversight of Regional and state programs, aimed at increasing
program effectiveness and national consistency.
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Regions and authorized states should:
Ensure the most serious environmental problems caused by noncompliance are addressed.
Regions should accomplish this primarily through annual planning with States, State
program oversight, strategic and targeted federal inspections and enforcement in States,
and through direct implementation in Indian country. Regions provide capacity-building
support to States on complex or multi-state issues; and consult with States to identify
compliance problems that may warrant areas of national focus. Regions should meet and
consult regularly (for example, quarterly) with each authorized State to maintain
communication on progress towards meeting annual permitting and enforcement
commitments, enhancing program performance and ensuring fairness and a level playing
field.
Take action to ensure serious violations are addressed where states are not meeting
performance expectations. Regions should focus oversight resources on the most pressing
performance problems in States and should work to demonstrably improve state
performance through these actions. Regions need to take action where States are not
addressing serious violations to communicate necessary improvements to state programs in
order to achieve goals of the federal environmental laws and ensure a level playing field
between States.
States are encouraged to report to the regions and OECA, any patterns of noncompliance
they may identify through their inspections or other activities.
Consistent with EPA's Policy on Consultation and Coordination with Indian Tribes;
OECA 's Guidance on the Enforcement Principles Outlined in the 1984 Indian Policy
(January 17, 2007), the Regions should consult, as appropriate, with potentially impacted
tribal governments when conducting inspections and addressing noncompliance at tribal
and non-tribal facilities in Indian country.
RCRA Corrective Action
RCRA corrective action is implemented by EPA and 43 authorized States and territories. The
National Enforcement Strategy for Corrective Action (NESCA) encourages EPA and States to
continue to work in partnership to achieve the 2020 Corrective Action goals and emphasizes the
need for close communication and coordination between EPA and States to meet this goal.
Regions should be working closely with their State partners to implement NESCA. NESCA
provides guidance to Regions and States for targeting enforcement efforts and to address special
considerations that arise in the enforcement arena, such as ensuring enforceable requirements
and deadlines in permits and orders are clearly identified and included, dealing with companies
having financial difficulties, using CERCLA authorities, ensuring institutional controls are
effective and enforceable and long-term stewardship requirements are met, and increasing the
transparency and community involvement of enforcement efforts. OECA will continue to
provide training to both Regions and States on how to review financial test and corporate
guarantee submissions for compliance. After 18 months of implementing NESCA, EPA and its
State partners plan to assess the contribution of NESCA in achieving progress toward the 2020
Corrective Action Goals. Necessary modifications to NESCA will be made and additional tools
and guidance documents may be developed as a result of this assessment.
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6. Improve Transparency
At the end of the fiscal year or when otherwise available, OECA will make essential information,
such as the following, available to the public via OECA's web page, or by other means:
Results of the State Review Framework;
Results of the Annual Commitment reporting;
Results and highlights of compliance assistance efforts; and
Highlights of significant EPA and State enforcement actions.
Regions are expected to use their own comparable existing mechanisms to inform the
public. States are encouraged to do likewise.
Compliance data should distinguish State information from Indian country information.
Information should be made available to communities, including Tribes, who lack access
to the internet.
7. Relevant Policies and Guidances
Additional information about OECA's RCRA programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/rcra/index.html
http://www.epa.gov/compliance/civil/rcra.html
http://www.epa.gov/compliance/cleanup
B. Toxic Substances Control Act (TSCA)
The Toxic Substances Control Act of 1976 provides EPA with authority to require reporting,
record-keeping and testing requirements; and restrictions relating to chemical substances and/or
mixtures; and the production, importation, use, and disposal of specific chemicals, including
lead-based paint, polychlorinated biphenyls (PCBs), and asbestos.
OECA addresses toxics problems through the following TSCA programs:
TSCA New and Existing Chemicals Programs (note: the term New and Existing
Chemicals Programs describes TSCA section 4, 5, 6, 8, 12 and 13), Subchapter I,
otherwise known as "core TSCA."
TSCA Lead-based Paint (LBP) Risk Reduction Program
TSCA Legacy Chemicals Program (PCBs and Asbestos Program which includes Worker
Protection Standards, the Model Accreditation Plan Program and the Asbestos Hazard
Emergency Response Act (AHERA))
Beginning in 2012, the TSCA programs will be managed nationally as one program rather than 4
distinct programs. The purposes of this change are to better leverage limited TSCA resources,
better coordinate enforcement activities across Regions and amplify the inspection and
enforcement presence. How these goals will be accomplished is discussed in the specific TSCA
sections below.
For Regional ACS planning purposes, Regions should target their 2012 TSCA ACS
commitments using a baseline of the last 3 years of their cumulative TSCA accomplishments
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(combined lead, new and existing chemicals, PCBs, and asbestos activities). If FY10 was
representative of the last 3 years of activity, it can be used as the baseline. Regions are expected
to have some investment in the TSCA program annually. The regions should then apply the
following recommended resource allocations:
The Regions should then apply the following recommended resource allocations:
60% of Regional inspections/enforcement actions should focus on lead based paint
with the majority being the Renovation, Repair and Painting (RR&P) rule.
25% of Regional inspections/enforcement actions should focus on PCBs including
used oil;
10% of Regional inspections/enforcement actions (for invested Regions) for New
and Existing Chemical should focus on Action Plan Chemicals or other targeted
priorities;
5% of Regional inspections, should focus on asbestos in schools and commercial and
state buildings in states without the Occupational Safety and Health Administration
(OSHA);
The region can deviate from this proposed allocation by up to 10% to allow for
flexibility for an investment in regional priorities (i.e., Region 5 PCBs in natural gas,
Region 2 PCBs in schools, etc.).
If flexibility beyond the recommended allocations above is needed, Regions should
contact OC to discuss.
COMMITMENT TSCA01: Project the number of FY2012 TSCA inspections.
1. Link with Office of Chemical Safety, Pesticides, and Prevention's Top Priorities
OECA addresses the Office of Chemical Safety, Pesticides, and Prevention (OCSPP) priorities
for TSCA programs in the following way:
Reduce Lead Risks: OECA provides overall direction to Regions and authorized states,
territories and tribes to promote compliance with all of the LBP rules with a significant
focus on the (RRP) rule.
Assess and Reduce Risks from New and Existing Chemicals: OECA focuses on
compliance with TSCA Section 5 with a particular focus on short chained and other
chlorinated paraffins, and other priority or Action Plan chemicals.
2. Aggressively Go After Pollution Problems That Make a Difference in Communities
TSCA's enforcement programs are significant to communities because they address chemicals
that can pose serious risks to human health. Lead-based paint is particularly dangerous to
children: exposure may cause reduced intelligence, learning disabilities, behavior problems and
slowed physical development. Because LBP is found in pre-1978 buildings, it is more common
in communities predominated by older housing, which usually are low-income, minority and EJ
communities. Asbestos in schools, if not properly managed, can expose children, teachers and
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other school staff to harm that may not manifest for years. PCBs bioaccumulate and thus cause a
variety of adverse health effects. Asbestos and PCBs are also generally found in older buildings.
Additionally, PCBs are generally found in older transformers, capacitors and some hydraulic
equipment and more recently in recycled and used oil. Inappropriate abatement and disposal of
asbestos and PCBs can be dangerous.
A national compliance monitoring strategy (CMS) for the TSCA program is being developed in
FY2011 that will include monitoring expectations, including ACS commitments, for regions in
FY2012. The CMS will cover all aspects of the TSCA compliance program.
a. TSCA New and Existing Chemicals Programs
The TSCA New and Existing Chemicals Program is exclusively a Federal program that provides
for review of the toxicity of chemicals prior to their manufacture and importation to prevent
unreasonable risk to human health and the environment. To assist the regions in targeting
inspections, OECA commits to working with OCSPP to obtain lists of facilities for targeting
inspections. Regions implementing the New and Existing Chemical Program should:
Focus TSCA compliance activities on chemical manufacturing, distribution, processing, use,
or disposal in emerging technologies and/or use of new chemicals.
Through inspections and enforcement actions as appropriate, focus on ensuring facility
compliance with:
o TSCA 5 - new chemicals requirements such as Pre-manufacturing Notice (PMN);
Significant New Use Rules (SNUR's); Low Volume Exemptions (LVE's), and on
chemicals of concern including short chained and other chlorinated paraffins, and
other priority or Action Plan chemicals or targets.
Target existing chemical reporting and record keeping requirements such as s TSCA 8(c),(d)
and(e) and the Inventory Update Rule;
Evaluate and prioritize tips and complaints and follow-up as appropriate. Targeting for
future inspections based on credible leads from tips and complaints should also be
considered. Regions implementing this program are also expected to follow-up on all
referrals received from headquarters, States, Tribes, and the public. Regions not
implementing this program should refer tips and complaints the Waste and Chemical
Enforcement Division within the Office of Civil Enforcement.
Obtain information through inspections and/or subpoena as appropriate. Initiate civil
enforcement actions, as appropriate, to bring facilities into compliance.
b. TSCA Lead Risk Reduction Program
Recent data show that tremendous progress has been made in the continuing effort to eliminate
childhood lead poisoning as a public health concern. Based on data from the Centers for Disease
Control (CDC), EPA has measured progress by tracking reductions in the number of children
with elevated blood lead levels (EBLLs) of 10 micrograms per deciliter or higher. Data released
in 2009 by the CDC indicate that the incidence of childhood lead poisoning, as defined above,
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has declined from approximately 1.6 percent of children in 2002 to 0.9 percent of children in
2006.
At the same time, however, new data are revealing adverse health effects to children at lower
lead levels than previously recognized. Thus, even though initial gains have been encouraging,
EPA wishes to achieve further reductions in the incidence of children with these lower, but still
significantly elevated BLLs. Monitoring and enforcement efforts to promote compliance with
LBP rules, particularly the RRP Rule, advance the goal of eliminating and preventing LBP
hazards, which are the primary single cause of childhood lead poisoning. These efforts, thereby,
support the Agency's mission to eliminate childhood lead poisoning.
Authorized states, territories, tribes, and Regions are expected to:
Participate in and support the national RRP compliance/enforcement strategy (under
development). The strategy establishes a sequence of coordinated activities aimed at
promoting compliance among specific sectors of the universe regulated by the RRP Rule, and
the pre-renovation education rule (PRE Rule)(ง 745.84), which is a component of the RRP
Rule. In implementing the national strategy, Regions are expected to focus their RRP/PRE
efforts in high-priority geographical areas with significant or wide-spread childhood lead
poisoning (e.g., lead "hot spots"). Also, in those geographical areas, Regions should employ
integrated strategies to monitor, enforce and achieve compliance with the other components
of the LBP program: the ง 1018 disclosure rule (745 Subpart F), and ง 402(a) abatement rule,
as appropriate for the Region and state/tribe.
Also, Regions should:
o Conduct at least 60 percent of LBP inspections for compliance with pre-renovation
education (PRE) requirements (ง 745.84), RRP recordkeeping and reporting
requirements (ง745.86), or work practice standards through on-site inspections (งง
745.85 and 745.227).
o Conduct no more than 40 percent of LBP inspections for the ง 1018 disclosure rule (ง
745 Subpart F).
o Section 1018-only inspections should be minimized, and linked with other LBP
compliance inspections whenever practical, to provide a more comprehensive
approach to addressing compliance with all applicable LBP regulations.
o Initiate civil enforcement actions, as appropriate, and whenever necessary to protect
communities by addressing and ultimately resolving violations of the RRP rule, PRE
Rule, Disclosure Rule, work practice standards (งง 745.85 and 745.227), and
recordkeeping and reporting requirements (งง 745.86 and 745.227(1)).
o Regions should work with authorized states and tribes to ensure they are familiar with
national guidance and implement their programs consistent with the guidance.
In addition, Regions should:
Conduct targeting consistent with the national RRP strategy, including the identification of
geographical lead poisoning hot spots.
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In areas where Regions conduct integrated strategies as part of the national RRP strategy or
otherwise, include methods to better target compliance activities, such as partnering with
state/tribal and local health departments and health care providers to identify lead hot spots
and individual properties associated with EBLL children.
Work with their LBP program counterparts to encourage states/tribes to seek authorization
for the RRP program.
Conduct appropriate oversight of authorized state/tribal Section 402 and 406 programs.
Because of variations in housing arrangements at federal facilities, particularly at some
military bases, regions should closely investigate the applicability of the LBP regulations to
the particular facilities housing.
c. Legacy Chemicals Program (PCBs and Asbestos)
The Legacy Chemicals Program attempts to lessen chemical risk and exposure through
reductions in use and safe removal, disposal and containment of certain prevalent, high-risk
chemicals, known generally as legacy chemicals. Some of these chemicals were used widely in
commerce and introduced into the environment before their risks were known
TSCA PCBs
PCBs are a persistent toxin (PBT) that bioaccumulates in food chains and poses serious risks to
human health and the environment. Although PCB manufacture is banned, certain uses
(transformers/capacitors) continue to be allowed under conditions which ensure that PCBs are
managed properly and not released into the environment. PCBs have also been identified in
building materials (caulk, paint, and insulation) and electrical equipment (fluorescent light
ballast capacitors and potting materials) used in schools, raising concerns over potential exposure
to school children, teachers, and other school staff. PCBs (including export for disposal) are of
international concern. In 2012, Regions are encouraged to identify, inspect and take enforcement
action on used or recycled oil containing PCBs. Over the past several years there has been a
significant quantity of fuel and other oil containing PCBs due to improper management. For this
reason, we are suggesting targeting PCBs in oil.
Regions are expected to:
Follow-up on tips and complaints based on potential risk, including spills. Response may
include referral to States that have TSCA PCB compliance monitoring grants for further
investigations.
Use targeting tools to identify the most important PCB sources, including PCBs in oil, to
conduct inspections in each state and Indian country, including use of screening
tools/approaches, such as the Environmental Justice Strategic Enforcement Assessment
Tool (EJSEAT), and other information, such as community input. For States with TSCA
PCB grants, investigative work may be provided by the State rather than EPA.
Each comprehensive strategic plan should describe at a minimum, how the Region will
cover all significant PCB commercial storage and disposal facilities within the plan's
cycle. These inspections may be conducted in conjunction with RCRA TSD inspections
provided the inspector comprehensively evaluates compliance with both programs.
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Continue to implement use of PCB Tablets and PCB inspection software in inspections.
TSCA Asbestos
Asbestos may be present in schools and, if disturbed and released into the air, poses a potential
health risk to school children, teachers, custodial staff, and others in the school. There are no
immediate symptoms of exposure; health effects may manifest 15 or more years after exposure.
EPA requires Local Education Agencies (LEAs) to inspect for asbestos. When asbestos is found,
LEAs must provide notification to parents and teachers, develop and implement management
plans so that asbestos is not disturbed, or is properly removed, during renovations or other
activities (i.e., drilling to install electrical or communications lines).
In addition, the TSCA asbestos worker protection regulations offer protection for certain state
and local government employees who are not protected by the Asbestos Standards of OSHA.
Employees who are involved in asbestos related construction activities, certain custodial
activities, or certain activities associated with asbestos-containing brakes and clutch plates are
employed in occupations that pose an increased risk of potential exposure to asbestos. State and
local government employers must ensure that the employees engaged in these potential asbestos
exposure activities comply with applicable OSHA standards in order to ensure their employee's
safety and minimize the potential for exposure to asbestos fibers while performing their job
functions.
Authorized States, Tribes, and Regions are expected to:
Within a reasonable period of time, investigate and respond (including taking
enforcement action where appropriate) to any tips/complaints containing allegations that
provide a reasonable basis to believe that a violation has occurred. Response may
include referral to States that have TSCA asbestos compliance monitoring grants.
Conduct inspections and take appropriate enforcement action in each State and in Indian
country to assure equitable protection and ensure compliance with the TSCA asbestos
regulations. State inspections under the TSCA Asbestos/AHERA grant can provide
coverage for those States instead of the Region.
States that have "waiver" status should enforce under their state law. States that are "non-
waiver" will forward their inspection reports to the regional office for appropriate
enforcement action, as necessary.
In addition, Regions are:
Encouraged to conduct compliance inspections (as an alternative to inspections of LEAs)
at state and local government facilities to monitor compliance with the asbestos worker
protection requirements in states where state and local government employees are not
protected by the Asbestos Standards of the OSHA;
Encouraged to coordinate, as appropriate, TSCA asbestos inspections at LEAs with
inspections being conducted under other TSCA programs (e.g., lead, PCB in caulk)
and/or CAA asbestos NESHAP inspections;
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Encouraged to provide adequate oversight of state/tribal programs; and
Encouraged to target inspections at LEAs with: building stock of an age that is more likely
to contain asbestos, particularly those that are undergoing renovation or energy efficiency
upgrades that may disturb asbestos; at LEAs that have never been inspected; at LEAs that
have not been inspected within the past ten (10) years; at LEAs that have previously been
found in violation and/or been subject to enforcement action; and at private, religious,
and charter schools. Websites for TSCA Asbestos Information on LEAs:
o Department of Education - Public School LEAs:
http://nces.ed.gov/pubs2010/pesagencies08/tables.asp
o US Charter Schools - Current number of Charter Schools, by State:
http://www.uscharterschools.org/pub/uscs_docs/sp/index.htm
o Parochial School and Diocesan Locator:
http://www.ncea.org/news/SchoolDiocesanLocator.asp and
http://www.catholicusa.com/catholic schools online/catholic schools.htm
Required to ensure that state and tribal inspectors who inspect on behalf of EPA are trained
and credentialed per Guidance for Issuing Federal EPA Inspector Credentials to Authorize
Employees of State/Tribal Governments to Conduct Inspections on Behalf of EPA (2004);
For inspections conducted with EPA credentials, review and provide feedback that
addresses the quality of the inspection/reports and the action taken by the Region, if any.
3. Reset Our Relationships with States
The Regions should work with States and Tribes to identify any obstacles to implementation of
the expectations above and work to resolve them. This includes convening routine and regular
meetings between the Region and States to discuss progress towards meeting annual program
and enforcement commitments, and how the State has been performing overall in its
implementation of the program.
The Grants Administration Division issued guidance for the TSCA grants program that becomes
effective on October 1, 2012. This guidance requires that negotiated grant workplans
prominently display the following three Essential Elements: Essential Element 1 - Strategic Plan
Goal; Essential Element 2 - Strategic Plan Objective; and Essential Element 3 - Workplan
Commitments plus time frame. Regional Program Offices must electronically enter workplans
and progress report information into an IT application currently being developed.
Where States are not meeting performance expectations, Regions should take action to enforce to
address serious violations. Regions should focus oversight resources to the most pressing
performance problems in States and should work to demonstrably improve state performance
through these actions. OECA and the Regions will use a variety of mechanisms to ensure
adequate oversight, including regular meetings and consultations with States/Tribes, grant
reviews and oversight inspections.
Regions should provide:
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Regional updates on actions and outcomes through discussions with OECA (generally,
through existing channels of communication).
Assurance that authorization agreements, which authorize employees of state and tribal
governments to conduct inspections on EPA's behalf, are in place with States and Tribes
that receive TSCA Compliance Monitoring grants for PCBs, and that training
requirements are met.
Review of state inspection reports, feedback to States, and enforcement actions as
appropriate, where inspections are conducted by States with EPA credentials.
Additionally, Regions should provide reports to OECA in accordance with Guidance for
Issuing Federal EPA Inspector Credentials to Authorize Employees of State/Tribal
Governments to Conduct Inspections on Behalf of EPA (2004).
Consultation with Tribes on the central role that enforcement and compliance plays in
EPA's direct implementation program and oversight of approved tribal programs.
On a program specific basis:
a. TSCA Lead-Based Paint Program (LBP)
To ensure national consistency, OECA's role is to provide appropriate oversight of Regional
LBP programs.
Regions should focus primarily on State/Tribal program oversight and capacity-building
to ensure States and Tribes are appropriately using tools to help ensure compliance, and
more importantly, integrating those tools to help effectively reduce elevated blood lead
levels (EBLLs) and LBP hazards in identified "hot spots"; support States/Tribes on
complex or multi-State/Tribal compliance issues; and consult with States/Tribes to
identify issues that may warrant areas of national focus in federal jurisdictions.
b. PCBs
Obtain early phase-out of PCBs as a condition of settlement.
Continue the use of electronic technology in the field.
c. TSCA Asbestos
Encourage States and Tribes to develop their own regulations and apply for a "waiver"
where applicable.
Ensure that authorization agreements, which authorize employees of state and tribal
governments to conduct inspections on EPA's behalf, are in place with states/tribes that
receive TSCA Compliance Monitoring grants for TSCA Asbestos (non-waiver states
only).
4. Improve Transparency
The Regions should:
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Work with the States and Tribes using EPA credentials to ensure that the data on
inspections they conduct on EPA's behalf is input into national databases. For waiver
States, ensure compliance and enforcement data are provided in aggregate form as part of
midyear and end of year evaluation reports. (Not applicable to lead program.)
Enter all federal inspections (including ICDS) and enforcement cases into ICIS.
Publicize regional enforcement actions taken through press releases.
Distinguish state compliance data from Indian country information.
Make information available to communities, including Tribes, who may lack access to
the internet.
5. Relevant Policies, and Guidances
Additional information about OECA's TSCA programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/tsca/index.html
http://www.epa.gov/compliance/civil/tsca/index.html
http://www.epa.gov/compliance/monitoring/programs/tsca/asbestoes.html
C. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
EPA and the public rely on pesticide manufacturers and formulators to provide accurate
information about pesticides and associated risks. Unregistered and ineffective pesticides,
as well as products making false or misleading public health protection claims, pose a potential
public health threat when the public makes inappropriate choices based on inaccurate or
misleading information. Products used in agricultural or structural pest control settings may pose
health risks to those working with or exposed to those chemicals.
A major focus of EPA's FIFRA program is to ensure compliance by pesticide registrants and to
provide assistance, training, and oversight to States and Tribes carrying out FIFRA related
compliance and enforcement activities under cooperative enforcement agreements. The statute
gives States primary compliance monitoring and enforcement responsibility for the use of
pesticides within their respective jurisdictions. Under FIFRA, EPA directly implements primary
use enforcement responsibility in Indian country. However, through enforcement agreements
with EPA, Tribes are allowed to enforce similar provisions under their own tribal codes.
1. Link with Top Office of Pesticide Programs Priorities
OECA addresses top Office of Pesticide Programs (OPP) priorities for the FIFRA program in the
following ways:
Effective Management of State and Tribal Grants/Cooperative Agreements: The FIFRA
State and Tribal Assistance Grant (STAG) Program seeks to assist states, territories, the
District of Columbia and Indian tribes in developing and maintaining comprehensive
pesticide programs that address all aspects of pesticide enforcement and special pesticide
initiatives, to sponsor cooperative surveillance, monitoring and analytical procedures, and to
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encourage regulatory activities within the states and tribes. OECA addresses this priority in
its State Grant Guidance, issued jointly with OPP.
Pesticide Occupational Worker Safety: FIFRA's Worker Protection Standards provide
critical protection to certain workers and handlers of pesticides in agricultural, nursery,
greenhouse, and forestry occupations. OECA addresses this priority in both the State Grant
Guidance and by including aspects of this priority in both the Fumigant/Fumigation and
Worker Safety focus areas of the NPM guidance.
Pesticide Container-Containment Regulation Implementation: Regulations covering
pesticide container and containment requirements are still being phased in and most
states/tribes are actively engaged in outreach and compliance assistance activities. OECA
addresses this priority in its State Grant Guidance and has included it as a focus area in the
NPM guidance.
Pesticides and Water Resource Protection: Protecting water bodies from pesticide
contamination helps assure the safety of those water resources. OPP has focused regulatory
efforts, including establishing restrictive use requirements, on key pesticides of concern. In
addition, a court ruling determined pesticides used in aquatic settings are not exempt from
regulation under NPDES. Activities are underway to develop a process to bring pesticide use
into compliance with the NPDES regulations. OECA recognizes protection of water
resources from pesticide contamination is important and, as part of its core pesticides
program, encourages the Regions to support State efforts to monitor compliance and enforce
against noncompliance.
Antimicrobial Hospital Disinfectants Efficacv/Misbranding: This area directly impacts
public health by ensuring the safe and effective use of disinfectants in hospitals. OECA has
been cooperating with OPP for several years in this effort and will take enforcement action
on products that fail efficacy testing, taking action in accordance with the December 2009
FIFRA Enforcement Response Policy. OECA will continue to support the antimicrobial
testing program through the core FIFRA compliance monitoring and enforcement program.
Soil Fumigation Compliance Assistance: Due to a re-evaluation of the risks associated with
the use of soil fumigants, OPP has required changes to product labeling and use directions for
highly toxic pesticides. In addition to compliance monitoring and enforcement relating to the
use of all fumigants, including soil fumigants, OECA is specifically addressing this priority
in the NPM guidance through encouraging outreach/compliance assistance activities to
support implementation of the new label changes for soil fumigants. Soil fumigation is
included in both the Fumigant/Fumigation and Worker Safety focus areas. OECA's State
Grant guidance also addresses soil fumigation through outreach, education, and compliance
activities.
2. Aggressively Go After Pollution Problems That Make a Difference in Communities
EPA will ensure compliance with and effective enforcement of FIFRA regulatory requirements.
The core program should include compliance and enforcement activities covering: pesticide
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registration and labeling, data quality requirements (FIFRA Good Laboratory Practice
Standards), efficacy and compositional integrity of hospital disinfectant products, pesticide
producing establishment registration and annual production data reporting, import and export
requirements, and registrant reporting of unreasonable adverse effects. The core program also
supports efforts to protect human health and the environment, including water resources, through
support and oversight of state and tribal monitoring and enforcement of pesticide use/misuse.
In conducting this work, Regions are expected to place special emphasis on the key focus areas
identified below. All Regions are expected to participate in Mandatory Focus Areas A and B
and to choose one additional area of participation from Optional Focus Areas C through F.
(State and tribes with cooperative enforcement agreements may also become involved in
supporting these activities, as appropriate, by including relevant activities in their negotiated
cooperative agreements.)
Mandatory Focus Area A: Imports
EPA's enforcement program continues to address the illegal importation of noncompliant
pesticide products into the United States by bringing enforcement actions against importers and
others; providing compliance assistance to manufacturers, importers and brokers; and working
with other governments, agencies and stakeholders to prevent and reduce risks of unsafe
products entering our country.
Importation of pesticides and devices is governed by FIFRA Section 17(c). All imported
pesticides intended for use in the United States must be registered as required by Section 3 of
FIFRA before being permitted entry into the U.S. Pesticide devices that are imported, although
not required to be registered, must be produced in a registered producing establishment, and must
not bear any statement, design, or graphic representation that is false or misleading in any
particular. Pesticides and devices must be properly labeled in accordance with FIFRA and Title
40 of the Code of Federal Regulations, Section 156. When importing pesticides or devices to the
U.S., the importer must submit to the appropriate EPA regional offices on EPA Form 3540-1
"Notice of Arrival (NOA) of Pesticides and Devices." Department of Homeland
Security/Customs and Border Protection (CBP) regulations prohibit the importation of pesticides
without a completed Notice of Arrival (NO A).
Illegal pesticide imports include a wide range of products, such as naphthalene mothballs and
related products (moth tablets, clothes hangers and urinal cakes), chlorine pool disinfectants,
insecticidal chalk, roach killers, mosquito coils and rat poisons. Illegal pesticide imports, which
can present significant human health and environmental risks; have been linked to poisonings of
children and pets resulting from use of these products.
EPA Regions will be the primary source of inspections and enforcement for this focus area.
States may become involved through Region-to-State referrals to monitor import compliance, or
States may encounter imported products during the course of their other compliance monitoring
inspections. EPA should make their States aware of EPA's strong interest in import compliance
and be should encourage them to cooperate and collaborate with EPA when situations warrant.
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Regions should work with U.S. Customs and Border Protection (USCBP) to identify pesticides
and/or pesticide devices in violation of FIFRA and prohibit illegal imports from entering the U.S.
channels of trade. Regions should conduct pesticide import inspections based on identified
targets at border crossings and other ports of entry, conduct sweeps and take samples, when
appropriate.
In addition, Regions should:
Monitor import compliance through inspections at the designated destination point for the
imported products. Such inspections would be conducted after the imported pesticides have
cleared U.S. Customs and have entered into the country.
Place special emphasis on compliance in Foreign Trade Zones.
Focus on importers with a history of noncompliance or significant importation activity from
countries frequently associated with noncompliant shipments.
Screen for potential discrepancies concerning country of origin sources for active ingredients
used to produce registered pesticides while reviewing Notices of Arrival (NOAs). Where
potential discrepancies are noted, follow-up production establishment inspections (PEIs) may
be warranted to further investigate the matter.
Conduct educational campaigns in urban neighborhoods that are at high risk for using illegal
imports to facilitate reporting of tips/complaints from the public about the sale/distribution of
illegal pesticide imports.
Take enforcement actions, as appropriate, to ensure optimum deterrence effect and
compliance impact.
Address noncompliance by taking enforcement action against violating import shipments and
then, when appropriate, develop cases that address corporate-wide noncompliant behavior.
Mandatory Focus Area B: Supplemental Registrations
Supplemental registrations are a continuous source of concern for regulators across the country.
States, which conduct thousands of marketplace inspections each year, have raised concern over
these labels for years, citing them as a major source of noncompliance. Supplemental
registrations are distributor labels approved for marketing as a sub-registration to a registered
pesticide. These products are marketed by the distributors using labels that are slightly modified
versions of the base product label. Although required to be consistent with the labels of the basic
registered products, distributors have frequently deviated substantially from the accepted labels.
Such unapproved revisions to the labels and product labeling can lead to misuse and
misapplication as well as pose significant risks to the users who rely on product labels to inform
them about proper and safe pesticide use. These labels have not historically been closely
monitored through the Agency's pesticide registration process. Due to the potential risk
associated with the use of improperly labeled pesticides, it is important that EPA aggressively
pursue compliance for supplemental registrations.
Supplemental registrations have been issued for a wide range of pesticide products, including
agricultural chemicals, pesticides used for residential pest control, lawn and garden pesticides, as
well as for disinfectants and other antimicrobial products. They also represent pesticides in
every toxicity category from Tox 1 Restricted Use Pesticides to minimal risk products.
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To address noncompliance in this focus area, emphasis will be placed on targeting registrants
with a large number of current supplemental registrations or registrants marketing Tox 1
category pesticides under distributor brand name labels and doing a comprehensive review of
those distributor label products. Product compliance will be determined through comprehensive
review of product labels and labeling and product chemistry, when appropriate.
Each Region will conduct PEIs and other marketplace inspections, as appropriate, and as
coordinated with the states, to monitor compliance in this focus area. States may wish to
participate, too, and can be a significant source of information about noncompliant supplemental
registration products.
Regions should monitor for label/labeling compliance, product composition, and compliance
with the provisions as described in to 40 CFR ง 152.132, including the restrictions on where and
how a supplemental distributor pesticide may be produced and packaged. This should include
any contract manufacturing agreement(s) that should be in place.
Enforcement actions should be developed to address corporate-wide compliance and not focus
on a single product noncompliance. In addition, Regions should coordinate with the Office of
Civil Enforcement's Waste Chemical Enforcement division and other Regions in developing
corporate-wide cases.
Regions are expected to take enforcement actions, as appropriate, to ensure optimum deterrence
and compliance impact.
Optional Focus Area C: Fumigants/Fumigation
Fumigants are a class of highly toxic pesticides that are efficacious in a gaseous stage, making
them very hazardous to handle and use. These products have a wide range of application use,
including treatment of residential structures, warehouses, transportation vehicles, grains and
other agricultural commodities, and soil. Improper or inadequate use directions and safety
precautions on the product labeling and improper use of these products often result in serious
exposure incidents potentially leading to death or hospitalization. Due to the potential risk
associated with fumigant use, it is critical that EPA and the States work collaboratively to
proactively monitor compliance with existing product labeling requirements, as well as proper
use of fumigant products.
In FY2008, OPP released a Reregi strati on Eligibility Decision (RED) that requires important
label changes incorporating significant new safety measures for soil fumigant pesticides to
increase protections for agricultural handlers, workers and bystanders (e.g., people who live,
work, or otherwise spend time near fields that are fumigated). The RED addresses the fumigant
pesticides chloropicrin, dazomet, metam-sodium/metam-potassium (methyl isothiocyanate), and
methyl bromide. Labeling changes required by the RED started appearing in the market place
in 2010, although EPA has delayed implementation of the second phase of required label
changes. Consistent with OPP's fumigant initiative, outreach and compliance monitoring will be
promoted to make users aware of future labeling changes for soil fumigants.
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Although the Soil Fumigant RED addresses significant regulatory changes for those products and
will require a focused effort to ensure compliance with the new safety requirements, the NPM
Guidance's fumigants/fumigation focus area is not primarily targeted on soil fumigant use
compliance. Instead, this focus area encompasses product regulatory compliance and
use/application compliance for all areas of fumigation including structural (residential and
commercial), transportation vehicles and containers, soil, agricultural commodities, and other
products.
Targeting should consider production factors (facility location, production volume, and product)
as well as use/application factors (use patterns of concern and volume/frequency of use). For
FY2012, participating Regions are expected to implement one or more of the compliance
monitoring approaches identified below and to initiate appropriate enforcement actions.
EPA has primary responsibility for monitoring compliance and initiating enforcement action
against violators of pesticide user requirements where states lack primacy and in Indian country
unless a Region and a tribe maintain a cooperative enforcement agreement. In addition, States
have primary responsibility for monitoring compliance and initiating enforcement action against
violators of pesticide use requirements (referred to as "primacy). Regions are encouraged to
determine whether there are opportunities for federal cases to support state efforts and initiate
federal cases that arise in Indian country. Federal involvement or support can provide significant
benefits by addressing noncompliance from a national corporate-wide perspective, facilitating
compliance efforts involving multiple States and/or Regions, and enhancing public awareness.
OECA will work with OPP to obtain FIFRA Section 6(a)(2) information across a broad class of
pesticide fumigants including structural, grain, and soil, among others. Section 6(a)(2)
information, together with information regarding fumigant incidents from the States, press and
other available sources, will help target fumigant uses where an enforcement monitoring
presence may significantly deter future violations.
Regions should work with their States to identify federal and state PEI opportunities, with
special emphasis placed on the priority fumigants frequently involved in exposure incidents (i.e.,
sulfuryl fluoride, methyl bromide, aluminum phosphide, zinc phosphide, metamsodium, and
chloropicrin). State PEIs can be applied toward meeting negotiated PEIs commitments within
existing cooperative agreements. PEIs conducted by regional inspectors will continue to help
build regional expertise. Physical sampling and analysis and documentary sampling is
encouraged. Physical samples of fumigant gases should not be taken; only documentary samples
of the labeling, container, and other appropriate materials should be sampled. Physical samples
of non-gas fumigants can be sampled and analyzed.
Regions should work with their States to identify opportunities for fumigation use/misuse
inspections in a variety of venues, with special emphasis on those use patterns frequently
associated with exposure incidents (i.e., residential buildings, commercial grain elevators and
granaries, on-farm granaries, seed warehouses, and agricultural crop soils). Where appropriate,
these State inspections may be applied toward negotiated cooperative agreement use/misuse
inspection commitments.
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When monitoring compliance in application settings subject to FIFRA's Worker
Protection Standards (WPS), such as on-farm use of grain or soil fumigants, compliance with the
WPS labeling requirements should also be monitored.
Consistent with the State Grant Guidance, States should conduct education, outreach
and compliance assistance activities for communicating the new labeling requirements for soil
fumigants. Although implementation of the soil fumigant RED labeling requirements will focus
on training and compliance assistance through FY2012, in instances of misuse or abuse,
appropriate enforcement response should be taken.
EPA should engage in each of the above actions where the Region directly implements the
FIFRA program, including in Indian country.
Enforcement actions should be pursued under both State and Federal authorities, as appropriate.
Similarly, EPA will pursue enforcement actions under FIFRA when noncompliance arises in
Indian country. Significant use or product compliance violations discovered during state or tribal
investigations should be considered for referral to EPA for federal enforcement, when
appropriate. Regions should work with States and Tribes to identify opportunities within
existing cooperative agreements for federal involvement or case support (particularly in cases
involving human exposure, death, or other serious non-compliance). Headquarters will provide
assistance, as needed, to States, Tribes, and Regions in support of enforcement actions.
Headquarters will develop a plan to coordinate filing of enforcement cases to ensure optimum
deterrence effect and compliance impact.
Optional Focus Area D: Worker Safety
Agricultural farm workers and pesticide applicators face a disproportionately high risk of
exposure to pesticides (from mixing, loading and applying pesticides; hand labor tasks in
pesticide treated crops; and pesticide drift from neighboring fields). Studies show that farm
worker families have higher levels of pesticide exposure than non-farm worker families (take-
home exposure transfer of pesticide residues and proximity of housing to treated areas). There
are 2 million farm workers in the US, over a million certified applicators, and 2-3 million
noncertified applicators applying pesticides under the supervision of certified applicators. It is
important to protect farm workers from occupational pesticide hazards to ensure their safety in
the workplace and viability as a community.
Under FIFRA, States with primacy enforce pesticide use, including the worker protection
standards. States with primacy also conduct compliance monitoring inspections. Regions are
encouraged to determine whether there are opportunities for federal cases to support state efforts.
Where EPA implements FIFRA, including in Indian country, the Agency enforces requirements
governing pesticide use and conducts compliance monitoring inspections. Tribes with
cooperative enforcement agreements with EPA may conduct compliance monitoring inspections
under their own tribal codes.
To optimize the risk reduction potential of compliance monitoring, Regions are expected to place
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particular emphasis on farming activities that typically involve frequent use of highly toxic
pesticides, such as in fruit and vegetable production and on-farm grain and soil fumigation.
Compliance monitoring and enforcement activities should include product and use
inspections.
Performance expectations for an active federal cooperative compliance/enforcement role within
the Worker Safety focus area include:
Regions should work with their state and tribal partners to target federal and state PEIs
(focusing on high toxicity pesticides subject to FIFRA's Worker Protection Standards
(WPS) labeling requirements and associated with high-risk applications/uses such as fruit
and vegetable production or on-farm grain and soil fumigation) to ensure label
compliance.
Regions should monitor use compliance in application settings (e.g., on-farm grain or soil
fumigation, applications to fruit and/or vegetable crops) subject to WPS and monitor
compliance with the WPS labeling requirements. Focus should be on pesticides with
high risk for exposure.
Enforcement actions should be pursued under State, Federal, or Tribal authorities, as
appropriate.
In order to optimize the deterrent impact of the enforcement action, significant misuse
violations should be investigated in a comprehensive manner to determine comprehensive
compliance with FIFRA.
States and tribes should be encouraged to refer use and non-use cases to EPA, when
appropriate.
Regions are expected to work with States to identify opportunities within existing
agreements for federal involvement or support (particularly cases involving exposure or
death).
Significant use or product compliance violations discovered during State or Tribal
investigations should be considered for referral to EPA for federal enforcement, when
appropriate.
Headquarters will provide assistance, as needed, to States, Tribes, and Regions in support
of enforcement actions.
State and tribal inspectors who inspect on behalf of EPA must be trained and credential
per Guidance for Issuing Federal EPA Inspector Credentials for Authorize Employees of
State/Tribal Governments to Conduct Inspections on Behalf of EPA (2004)
Optional Focus Area E: Retail Marketing
Until recently, EPA has focused enforcement against the producer or registrant of violative
product(s). However, retailers of noncompliant products must also comply with FIFRA. One
action against a retailer may result in bringing numerous pesticides into compliance with FIFRA.
Taking enforcement at the retail level, as well as at the producer or registrant level, can have a
very significant impact on gaining product compliance. Deterrence likely increases due to
heightened end-use consumer awareness and the adverse publicity generated against the retail
store, the product, and the manufacturer.
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Retail marketers of pesticide products are positioned to directly interact with the consuming
public, so any enforcement action taken against products being offered for sale is quickly noted
by the buying public and, as a result, purchasing patterns of the consumers can be quickly
altered, thus creating a significant financial impact on all businesses with a financial interest in
the distribution and sale of the pesticide product(s) involved. This provides a tremendous
incentive for registrants to quickly return the product(s) to compliance so that a positive business
relationship with retailers can be preserved and a positive image can be presented and/or restored
with the consuming public.
Regions should focus on national or regional retail chains operating multiple stores nationwide
or in a multi-state area. Such stores often market similar products throughout their network of
stores so that compliance issues can have corporate-wide implications. Such consumer-based
retail stores typically offer a wide variety of pesticide device products, so addressing
noncompliance at this level can immediately impact multiple pesticide producers.
Alternatively, Regions may elect to target major distributors who sell directly to specialized
niche markets rather than to the general public. Examples of these retailers might be distributors
that sell pesticide products and other supplies directly to hospitals, beauty salons and barber
shops, funeral homes, and restaurants. These industries typically do not deal directly with
traditional retail outlets for their supplies but instead purchase from specialized niche
distributors. These direct-retailers often handle very specialized products not commonly found
in the retail stores targeted to the general public and, as a result, compliance may not be as
closely monitored. Additionally, many of these retailers handle distributor-label disinfectants, a
product sector which has a long history of noncompliance.
Performance expectations for the retail marketing focus area include:
Regions should conduct compliance monitoring inspections at targeted retailers.
Regions should work with their state and tribal partners to encourage producer
establishment and marketplace inspections in support of this focus area, including
targeting follow-up PEIs at producers of violative products discovered at the retail
inspections. Regions may consider making inspection referrals to the states/tribes to
follow-up on leads and otherwise supplement federal efforts.
Regions are expected to take enforcement actions, as appropriate, to ensure optimum
deterrence effect and compliance impact.
Optional Focus Area F: Container/Containment
To ensure effective implementation of the new container/containment regulations, Regions,
states and tribes should monitor compliance with the requirements in all areas of the regulated
universe and for all aspects of the container/containment rule. In particular, inspections should
focus on compliance with container design and labeling, residue removal, and containment
requirements for registrants, re-fillers, agricultural retailers, commercial applicators, and custom
blenders, as appropriate. User inspections, conducted by states and tribes, should focus on
compliance with label directions for storage, cleaning, and disposal of containers.
States and tribes have been actively addressing the new regulations and are likely to continue
that emphasis under the State Grant Guidance.
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For Regions electing to participate in the container/containment focus area, performance
expectations include:
Conducting compliance monitoring inspections at targeted producers, distributors, and
other regulated non-user entities subject to the container/containment rule.
Working with states and tribal partners to encourage a full range of user and non-user
inspections to monitor all aspects of compliance for the container/containment rule in
support of this focus area. States and tribes should be encouraged to refer significant
noncompliance cases to EPA for enforcement action.
Taking enforcement actions, as appropriate, to ensure optimum deterrence effect and
compliance impact.
Commitment FIFRA-FED1: Project regional (federal) FIFRA inspections, including those at
federal facilities. Each Region should conduct a minimum often (10) FIFRA inspections. In the
Comment Section, provide the number of federal facility inspections.
3. Reset Our Relationships with States
The Regions should work with States and Tribes to implement the expectations above, including:
Convene routine and regular meetings between the Region and State to discuss progress
towards meeting annual program and enforcement commitments, and how the State has
been performing overall in its implementation of the program. Note: meetings can be via
conference calls but at least one meeting each year should be face-to-face. Regions may
rely upon existing communications with states to meet the intent of this requirement.
Where States are not meeting performance expectations, Regions should take
enforcement to address serious violations. Regions should focus oversight resources on
the most pressing performance problems in States and should work to demonstrably
improve state performance through these actions. Regions need to take action when
necessary to communicate what needs attention to achieve the goals of the federal
environmental laws and to ensure a level playing field among States.
Negotiate, oversee the implementation of and review state and tribal performance under
the pesticide enforcement cooperative agreements following existing policy and
guidance.
When doing mid- or end-of-year reviews, include a review of cases based on complaints
by farm-workers and those involving one of the NPM guidance focus areas to evaluate
whether the enforcement response was appropriate.
Provide States and Tribes targeting assistance, especially related to inspections of
producer establishments.
Consistent with EPA's Policy on Consultation and coordination with Indian Tribes;
OECA's Guidance on the Enforcement Principles Outlined in the 1984 Indian Policy
(January 17, 2001; and Questions and Answers on the Tribal Enforcement Process (April
17, 2007), the Regions should consult, as appropriate, with potentially impacted tribal
governments when conducting inspections and addressing noncompliance at tribal and
non-tribal facilities in Indian country.
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4. Improve Transparency
Currently, OECA is exploring ways to modernize and update databases that contain information
on pesticide inspections and enforcement action by state and tribal grantees FIFRA-TSCA
Tracking System/National Compliance Database (FTTS/NCDB) that will improve data quality,
and provide more timely data entry and public access. Regions are
expected to continue to assure the timely and accurate entry of state and tribal performance data
and their own federal inspection and enforcement data.
Regions should assure timely and accurate entry of state and tribal performance data and federal
inspection and enforcement data.
5. Relevant Policies and Guidances
Additional information about OECA's FIFRA programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/fifra/index.html
http://wwwp.epa.gov/compliance/monitoring/programs/fifra/wps.html
http://www.epa.gov/compliance/civil/fifra/index.html
Policies and guidance pertinent to the FIFRA focus areas can be found at the following:
FY2011-2013 Grant Guidance:
http://www.http://www.epa.gov/compliance/state/grants/fifra.html
FIFRA Enforcement Response Policies:
FIFRA State Primacy Enforcement Responsibilities: Final Interpretive Rule:
http://www.epa.gov/compliance/resources/policies/state/grants/fifra/1983frnotice.pdf
Procedures Governing the Rescission of State Primary Enforcement Responsibility for
Pesticide Use Violations:
http://www.epa.gov/compliance/resources/policies/state/grants/fifra/1981frnotice.pdf
EPA WPS Agricultural Inspection Guidance:
http://www.epa.gov/compliance/resources/policies/state/grants/fifra/08-10-appendix4c.pdf
Factors To Consider When Establishing A Risk-Based Targeting Strategy For Worker
Protection Outreach And Compliance Monitoring Activities:
http://www.epa.gov/compliance/resources/policies/state/grants/fifra/08-10-appendix4d.pdf
Multilingual Labeling for Imports:
http://www.epa.gov/compliance/resources/policies/monitoring/fifra/imports/multilanglabel.pdf
Questions and answers on supplemental labeling, effective date, registration status for
labeling purposes, foreign purchaser acknowledgement statements, and confidentiality:
http://www.epa.gov/compliance/resources/policies/monitoring/fifra/imports/supplabel.pdf
Questions and answers on research and development pesticides and active ingredient
concentrations:
http://www.epa.gov/compliance/resources/policies/monitoring/fifra/imports/ai.pdf
FY2012 OECA NPM Guidance Page 64
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FIFRA Inspection Manual:
http://www.epa.gov/compliance/resources/publications/monitoring/fifra/manuals/fifra/index.html
WPS Inspection Manual:
http://www.epa.gov/compliance/resources/publications/monitoring/fifra/manuals/wps/index.html
Project Officer Manual: http://intranet.epa.gov/oeca/oc/ag/manual.html
FY2012 OECA NPM Guidance Page 65
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D. Specific Comprehensive Environmental Response Compensation and Liability Act
(CERCLA) Enforcement Program Performance Expectations
1. Link with Top OSWER Priorities
OECA addresses top OSWER priorities for CERCLA in the following ways:
Land Revitalization: Through its Brownfields program, EPA will continue to provide for
the assessment and cleanup of Brownfield sites, to leverage redevelopment opportunities,
and to help preserve green space, offering combined benefits to local communities.
OECA can facilitate reuse by clarifying liability at sites of federal interest (or for
communities particularly impacted by the economic downturn), when perceived liability
remains an obstacle and EPA involvement is critical. Brownfields are described in more
detail in the Goal 3 NPM Guidance published by OSWER.
Cleaning Up Our Communities: In an effort to improve the accountability, transparency,
and effectiveness of EPA's cleanup programs, EPA initiated a multiyear effort in 2010 to
better use assessment and cleanup authorities to address a greater number of sites,
accelerate cleanups, and put those sites back into productive use while protecting human
health and the environment. By bringing to bear the relevant tools available in each of
the cleanup programs, including enforcement, EPA will better leverage the resources
available to address needs at individual sites.
2. Aggressively Go After Pollution Problems That Make a Difference in Communities
EPA's CERCLA Enforcement program protects communities by requiring responsible parties to
conduct cleanups, preserving federal dollars for sites where there are no viable contributing
parties. Superfund enforcement ensures prompt site cleanup and uses an "enforcement first"
approach that maximizes the participation of liable and viable parties in performing and paying
for cleanups. EPA negotiates cleanup agreements with potentially responsible parties at
hazardous waste sites and, where negotiations fail, either takes enforcement actions to require
cleanup or expends Superfund appropriated dollars to clean up the sites. In some cases, EPA
takes both actions. When EPA uses appropriated dollars, it takes action against any viable
responsible parties to recover cleanup costs. Aggressively pursuing responsible parties to clean
up sites ultimately reduces direct human exposure to hazardous pollutants and contaminants,
provides for long-term human health protections and makes contaminated properties available
for reuse.
As part of the Integrated Cleanup Initiative (1C I), OECA will take early and focused enforcement
efforts to compel cleanup. Those efforts include increasing enforcement earlier in the pipeline at
non-emergency removal action and remedial investigations/feasibility study (RI/FS) stages;
expediting remedial action by holding parties accountable to negotiation timeframes and
scheduled cleanup commitments; and rejuvenating the process for early identification of
FY2012 OECA NPM Guidance Page 66
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responsible parties to support increased site assessment, national priorities (NPL) listings, and
early enforcement activities.
Under the ICI, OECA is reaffirming its commitment to "enforcement first" in all aspects of the
Superfund program (i.e., removals, remedial, long-term stewardship, etc.). Regions should
continue to focus on activities that maximize PRP involvement at Superfund sites.
EPA's Superfund enforcement GPRA goals and performance expectations for FY 2012 are:
COMMITMENT OSRE-01: Reach a settlement or take an enforcement action by the start of
remedial action at 99% of non-federal Superfund sites that have viable, liable parties.
COMMITMENT OSRE-02: Address all unaddressed costs in Statute of Limitations cases for
sites with total past Superfund costs equal to or greater than $200,000 via settlement, referral to
DOJ, filing a claim in bankruptcy, or where appropriate write-off.
COMMITMENT HQ-VOL: Volume of Contaminated Media Addressed (VCMA): As part of
the Goal 5 sub-objective, Support Cleaning up Our Communities, OECA has added the
following new GPRA target:
By 2015, obtain commitments to clean up 1.5 billion cubic yards of contaminated soil and
groundwater media as a result of concluded CERCLA andRCRA corrective action enforcement
actions.
OECA has reported VCMA for contaminated soil and groundwater media as separate measures
in its annual results since 2004. The new measure combines the two and elevates them to the
GPRA level. The GPRA target is a national target and regions are not required to post
commitments in ACS.
In addition, the CERCLA enforcement program tracks many program-level measures. These
measures and their definitions can be found in the Superfund Program Implementation Manual
(SPEVI) at: http://epa.gov/superfund/action/process/spiml 1 .html.
OSWER's National Program Managers Guidance for FY2011 establishes priorities for EPA's
Federal Facilities Response program: conducting cleanup and response work at contaminated
sites and rendering formerly contaminated sites Ready for Reuse. EPA has Federal Facility
Agreements in place at almost all Federal facility NPL sites regarding the cleanups conducted by
the facilities and EPA's oversight of those cleanups. Those agreements lay out procedures for
resolving disputes. Regions are expected to use the procedures of the agreements, or other
applicable enforcement authorities (such as imminent and endangerment orders in applicable
circumstances), when Federal facilities are not complying with the terms of the agreements or
with other legal requirements. Additionally, Regions and headquarters offices should work
together to get remaining NPL sites as well as new NPL sites under agreements or other legally-
enforceable agreements.
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Environmental justice (EJ) is a priority for OECA's waste programs, promoting healthy and
environmentally sound conditions for all people. OECA will continue to integrate environmental
justice into its Site Remediation Enforcement program by:
Affirming its commitment to ensure that Regions and States use EJ criteria when
enforcing RCRA corrective action requirements to meet RCRA 2020 goals.
Affirming its commitment to ensure that institutional controls are implemented at sites in
environmental justice areas of concern.
Conducting an environmental justice review of new policy and guidance documents
before they become final.
3. Working With States, Tribes and Local Communities
EPA will be implementing its Community Engagement Initiative,
http://www.epa.gov/oswer/docs/cei action_plan 12-09.pdf designed to enhance headquarters
and regional program engagement with States, local communities and stakeholders to
meaningfully participate in government decisions on land cleanup, emergency response, and the
management of hazardous substances and waste. The initiative provides an opportunity for EPA
to refocus and renew its vision for community engagement, build on existing good practices, and
apply them consistently in EPA processes. Proactive, meaningful engagement with States, local
governments and communities will enable EPA to obtain better information about the
environmental problems and local situations - leading to more informed and effective policies
and decisions.
4. Improve Transparency
The Comprehensive Environmental Response Compensation and Liability Information System
(CERCLIS) is the main database for Superfund information. The public can request specific
reports by going to http://www.epa.gov/superfund/. In addition, Regions should continue to
provide site-specific fact sheets, which include enforcement information, on regional web pages.
Compliance data will distinguish State information from Indian country information. Information
should be made available to communities and Tribes, who lack access to the internet.
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SECTION VI: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS
ENVIRONMENTAL PROBLEMS THROUGH CRIMINAL ENFORCEMENT
1. Criminal Enforcement Priorities
The criminal enforcement program will emphasize:
EPA's Enforcement Goals, National Enforcement Initiatives for FY 2012-13 and
Regional Enforcement Priorities
Focusing Enforcement through Case Tiering
Integrating Environmental Justice (EJ) into case selection and prosecutions
Case Tiering. During FY 2012, the criminal enforcement program will continue to implement
and refine its case "tiering" system to focus scarce investigative resources using criteria, data and
methodologies linked to OECA's goals. The objective is to focus enforcement efforts by
increasing the percentage of Tier 1 and Tier 2 cases, which became a GPRA measure beginning
in FY 2011.
The case tiering methodology prioritizes cases based on four categories of information:
1) Human health and environmental impacts (e.g., death or serious injury),
2) The nature of the pollutant and the release, (e.g., toxic pollutant, continuing violation)
3) Subject characteristics (e.g., national corporations, repeat violators), and
4) Unique Case Factors (e.g., collaborative efforts with law enforcement partners)
Based on these factors, all cases are "tiered" with Tier 1 cases being the most important. The tier
designation is used throughout the investigative process including the opening of leads, case
selection and prosecution and direction of resources for case support. (Note: a case's tier
classification may change as cases are investigated and additional information uncovered).
Environmental Justice: One of the main duties of EPA's criminal enforcement program is to
serve and protect the most vulnerable communities by using law enforcement tools to protect
their health and local environment. EJ is a critical concept in meeting that objective. Criminal
enforcement will increase its use of the Agency's environmental justice tools and methodology
to help identify critical criminal cases that disproportionately impact vulnerable communities.
This includes continuing efforts to work with tribal law enforcement to strengthen the
effectiveness of environmental enforcement in Indian country. The program will also continue to
work with Agency EJ workgroups and partnerships to integrate and focus EJ efforts.
1. Link with Critical Program Office Priorities
EPA's enforcement program relies on the criminal and civil programs working closely together
both at the strategic and case-specific levels to bring to bear the most appropriate enforcement
tools to protect human health and the environment in each media area.
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At the national level, the criminal enforcement program will continue working with civil
partners in annual planning efforts and will work together to develop systems to track, encourage
and reward effective cooperation. Efforts will include assessing existing information available in
both criminal and civil programs and evaluating regional cooperative efforts to date. Each
program will adhere to OECA's parallel proceedings policy when both civil and criminal
violations are present in an individual case, and will ensure all civil and criminal staff are trained
on parallel proceedings.
At the Regional level, the enforcement offices will work with the Special Agents In Charge
(SACs) to continue and strengthen joint case screening, share salient information and plan how
to address violations using the most appropriate administrative, civil or criminal enforcement
tools.
2. Strengthen Relationships with Law Enforcement Partners That Support State
Environmental Crimes Investigations and Prosecutions
The criminal enforcement program will work with the States, Regions, Tribal governments, and
other law enforcement organizations as appropriate to:
Help these organizations build capacity to pursue environmental crime and provide
investigative support to state-lead prosecutions where appropriate.
Provide targeted training to State, tribal and law enforcement partners to enhance their
abilities to safely spot, report and address environmental violations.
Continue international enforcement efforts, e.g., working with INTERPOL to combat the
illegal transnational shipment and disposal of electronic waste (e-waste), work with
Canadian authorities in efforts in the Great Lakes.
3. Improve Transparency
The criminal enforcement program will:
Publicize EPA's criminal enforcement efforts and successes to deter other potential
violators.
Continue to develop its use of new outreach methods such as Facebook, twitter and
mobile applications to encourage the public's reporting of potential violations and to
provide leads through the fugitives web site.
Ensure that the public can continue to find information it needs about EPA's criminal
enforcement efforts, including the Summary of Criminal Prosecutions, the mobile
application of the Report a Violation Website and the EnviroCrimes Mapper.
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SECTION VII: KEY PROGRAM PRIORITIES AND STRATEGIES TO ADDRESS
ENVIRONMENTAL PROBLEMS THROUGH THE NATIONAL ENVIRONMENTAL
POLICY ACT
A. Specific Federal Activities Program Performance Expectations
Federal activity compliance work focuses on three areas: fostering compliance and pollution
prevention through international cooperation; assisting other federal agencies in making
environmentally sound decisions which include early public involvement and transparency by
complying with the National Environmental Policy Act (NEPA); and guiding EPA's own
compliance with NEPA and applicable statutes and Executive Orders. This work implements
two of OECA's FY 2012 goals by addressing pollution that matters most to communities and
promoting transparency.
Regions should work to assure international compliance and prevent illegal trans-boundary
movement of hazardous waste by:
Improving environmental performance and cooperation in accordance with Goal 6 of the
U.S./Mexico Border 2012 plan (Regions VI and IX).
Enhancing enforcement, compliance, and capacity building efforts with Mexico and Canada
relating to trans-boundary compliance monitoring on the U.S. borders for hazardous waste,
CFCs, selected chemicals (e.g., PCBs, mercury), and other regulated substances (Border
Regions).
Improving performance of joint responsibilities along the border and ports of entry into the
United States by working with the Bureau of Customs and Border Protection (CBP) through
appropriate contact channels (all Regions).
Promoting international environmental enforcement through participation in relevant
organizations and networks, such as the Enforcement Working Group of the North American
Commission for Environmental Cooperation (CEC) and the International Network for
Environmental Compliance and Enforcement (INECE), and, in particular, its Seaport
Environmental Security Network (regional participation as appropriate, based on subject
matter).
Reviewing the permit and compliance status of U.S. receiving facilities in connection with
100% of the notifications for the import of hazardous waste they receive from HQ EPA and,
based on the review, recommending consent or objection to notifications within the time
periods allowed under applicable international agreements (all Regions).
As a regular part of Regional inspection activities, conducting periodic inspections of U.S.
facilities which receive imported hazardous waste (TSDFs) and generators and other primary
exporters of hazardous waste, cathode ray tubes (CRTs) and spent lead acid batteries
(SLABs), based on information provided by OFA which identifies those facilities
participating in import and export shipments.
Regions should implement the National Environmental Policy Act (NEPA) by:
Fulfilling EPA's obligations under NEPA, Section 309 of the Clean Air Act, and cross-
cutting laws, directives, and Executive Orders (e.g., Endangered Species Act, National
Historic Preservation Act, Executive Order on Environmental Justice, Wetlands and Flood
FY2012 OECA NPM Guidance Page 71
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Plains Protection) by reviewing and commenting on all major proposed federal actions to
ensure identification, elimination, or mitigation of significant adverse effects, and making the
comments available to the public.
Ensuring that projects likely to have significant impacts (e.g., transportation, mountaintop
mining, and energy) receive sound environmental analysis, use cooperation among agencies
to resolve differences, consider environmental justice, incorporate innovation and support
public involvement through a more streamlined and transparent environmental review
process
Ensuring that at least 90 percent of EPA projects subject to NEPA environmental assessment
or EIS requirements (e.g., water treatment facility projects and other grants, new source
NPDES permits and EPA facilities) are expected to result in no significant environmental
impact.
Ensuring that 70 percent of significant impacts identified by EPA during the NEPA review
of all major proposed federal actions will be mitigated. (GPRA measure)
Promoting Environmental Justice considerations throughout the environmental decision-
making process and encouraging public involvement early in the process to maximize
transparency.
Working towards the goals laid out in EJ 2014, particularly the commitments regarding
cross-Agency coordination to meet the challenges of the Executive Order.
Fostering cooperation and collaboration with other Federal agencies and
Tribes to ensure compliance with applicable environmental statutes; promoting better
integration of pollution prevention measures and ecological risk assessment; and providing
technical assistance in developing projects that prevent adverse environmental impacts to the
Nation's land, water and air.
Making categorical exclusion determinations or preparing environmental analyses (EISs or
EAsj and posting them on the internet for EPA- issued National Pollutant Discharge
Elimination System (NPDES) permits for new sources, for states/tribes without authorized
NPDES programs; off-shore oil and gas sources, including permits for deepwater ports, EPA
laboratories and facilities; and Clean Water Act wastewater treatment plant grants.
Making Categorical Exclusion determinations or preparing environmental analyses (EAs or
EISs) and posting them on the internet for Special Appropriation grants (including the
Colonias Wastewater Construction and Project Development Assistance program) for
wastewater, drinking water supply, and solid waste collection facilities; Border Environment
Infrastructure Funds (for the US/Mexico Border Environment Cooperation Commission
projects); and reviews conducted under "EPA's Voluntary NEPA Compliance Policy."
Entering the results of their ' 309 reviews and NEPA compliance actions into the Lotus
Notes EIS Tracking Database maintained by HQ OF A, and the Special Appropriations Act
Projects (SAAP) system maintained by HQ OW, respectively. Additionally, Regions should
report to the Office of Federal Activities quarterly on the status of their 309 reviews and
NEPA compliance actions pursuant to the Government Performance Reporting Act (GPRA)
reporting process, and provide other reports as may be required by the American Recovery
and Reinvestment Act of 2009.
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SECTION VIII: NATIONAL PROGRAM REQUIREMENTS FOR ADDITIONAL OECA
PROGRAMS UNDER GOAL 5
In addition to the national initiatives and programs that can be specifically assigned to one of the
four Strategic sub-objectives of water, air, waste/toxic/pesticides, and criminal enforcement,
OECA has several programs that contribute to the goals of more than one sub-objective. These
programs are: Multi-media, Compliance Incentives, Indian country, and Emergency Planning
and Community Right to Know Act (EPCRA). In addition, OECA has specific training and state
oversight program requirements.
A. Specific Emergency Planning and Community Right to Know Act (EPCRA) Program
Performance Expectations
EPCRA includes two distinct programs, Community Right-to-Know under EPCRA 313 and
release notification and emergency preparedness under CERCLA 103 and EPCRA 304, 311 and
312. EPA and the public rely on EPCRA for information on chemical releases entering the
environment, and on the storage of chemicals at facilities. EPA, States, Tribes, local entities, and
communities rely on the combined EPCRA/CERCLA information to prepare local chemical
emergency response plans, and to more safely and adequately respond to chemical emergencies.
EPA must ensure that companies report accurately and within required time frames. Although
there is no target for assistance activities, assistance is an appropriate tool, in particular, for
smaller entities who meet the reporting criteria. Regions and States should inspect facilities that
may be contributing to pollution problems that matter to their respective communities, and
develop enforcement cases that produce significant environmental benefits.
1. Link with Top Office of Environmental Information Priorities
OECA addresses the top Office of Environmental Information priority for the EPCRA programs
by increasing compliance of non-reporters.
2. Aggressively Go After Pollution Problems That Make a Difference in Communities
A. EPCRA 313:
Regions are expected to:
o Inspect or send information request letters to enforcement targets developed by
OECA with assistance from OEI for FY 2012 to address the following categories of
concern as resources allow.
o Potential non-reporters (facilities that report in one year but fail to report the
following year).
o Potential never-reporters (target facilities in the same sectors where a company may
not have reported and a similar facility in the sector did report);
o Potential data quality issues (facilities with significant changes in release estimates
from one year to the next or facilities in the same sector where a facility reports
significantly more/less than a similar facility in the sector).
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o Facilities that submit a Form A after having previously submitted a Form R, and
concerns exist as to the accuracy of this change.
o The submission of forms with errors significant enough to prevent the input of data
into the Toxic Release Inventory.
Track and prioritize tips and complaints and follow-up, as needed. OECA may provide
additional targeting as part of an initiative focused on communities, chemicals or sectors
of concern.
Any inspections resulting from any of these targeting efforts will count towards the
Region's overall inspection commitments.
In addition, Regions should:
Work with the Air, RCRA and Water compliance and enforcement programs to add EPCRA
questions to information requests where appropriate, evaluate the responses, and take
appropriate enforcement actions or combine with other enforcement actions.
Review and follow-up on, as appropriate, disclosures submitted under the OECA Audit
Policy and Small Business Policy.
OECA will assist in targeting inspections, but the Regions are expected to provide legal
and technical enforcement case support, and either obtain additional information through
federal investigation, show cause letter, subpoena and issue appropriate federal actions as
appropriate; or determine that follow-up is not necessary.
COMMITMENT EPCRA 01: Conduct at least four (4) EPCRA 313 data quality inspections.
COMMITMENT EPCRA 02: Conduct at least twenty (20) EPCRA 313 non-reporter
inspections.
B. EPCRA 304/311/312 CERCLA 103
Regions should:
Use screening and targeting tools to focus limited federal resources on national and
regional priority areas. In targeting for inspections, Regions should consider the presence
of significant quantities of CERCLA hazardous or EPCRA extremely hazardous
chemicals, proximity to population centers, a history of significant accidental releases,
and any other information that indicates a facility may be high-risk.
Evaluate compliance with EPCRA sections 304, 311, and 31 and CERCLA section 103
during CAA section 112(r) high-risk facility inspections (as described in the CAA
Section of this guidance).
Within a reasonable period of time, evaluate and respond, if appropriate (including taking
enforcement action where appropriate) to any tip or complaint containing allegations that
provide a reasonable basis to believe that a violation has occurred.
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Evaluate certain continuous release submissions for accuracy and compliance and take
appropriate enforcement actions for non-compliance.
3. Reset Our Relationships with States
The Regions should continue coordinating with States and Tribes.
4. Improve Transparency
The Regions should
Enter all federal enforcement cases into national databases.
Enter all federal civil judicial consent decrees into ICIS.
5. Relevant Policies and Guidances
Additional information about OECA's EPCRA programs can be found at:
http://www.epa.gov/compliance/monitoring/programs/epcra/index.html
http://www.epa.gov/compliance/civil/epcra/index.html
http://www.epa.gov/compliance/monitoring/programs/epcra.html
B. Compliance Incentives Program Performance Expectations
In addition to providing compliance assistance and taking enforcement actions, EPA promotes
compliance through the use of the following incentive policies: (1) the policy on "Incentives for
Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations" (the Audit
Policy); (2) "Small Business Compliance Policy" (Small Business Policy); and (3) "Small Local
Governments Compliance Assistance Policy" (Small Local Governments Policy). These policies
reduce or waive penalties under certain conditions for facilities which voluntarily discover,
promptly disclose, and correct environmental problems. EPA encourages the use of these
policies, particularly when use results in actions that reduce, treat, or eliminate pollution in the
environment or improve facility environmental management practices (EMPs).
In most quarters, EPA receives slightly more self-disclosures than are recorded as resolved.
Over time, this has led to an increasing inventory of unresolved disclosures. In recognition that
we need to address this inventory, the Audit Policy Coordination Team (ACT), comprised of
representatives from all ten Regions and Headquarters has developed a number of practice
modifications, which should reduce transaction costs, streamline and speed up the processing of
disclosures. In FY 2011, the Office of Civil Enforcement will continue to work with the Regions
and Headquarters offices to expedite the processing and resolution of voluntary disclosures. In
FY 2012, the Regions and Headquarters are expected to continue to expeditiously process
voluntary disclosures in order to prevent the increase of the pipeline, as well as to reduce the
inventory.
1. Aggressively Go After Pollution Problems That Make a Difference in Communities
EPA's Audit Policy, Small Business Policy and Small Local Governments Policy provide
incentives for regulated entities to resolve environmental problems and come into compliance
with federal laws through self-assessment, disclosure, and correction of violations. EPA is
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encouraging audits and disclosures that achieve significant environmental outcomes, as well as
ways to improve Audit Policy implementation.
Under various Compliance Incentive Programs (CIPs), individual entities or members of a sector
disclose and correct violations in exchange for reduced or waived penalties, while the risk of
enforcement increases for those not taking advantage of this opportunity. Regions in
consultation with Headquarters are expected to consider the use of CIPs directed at particular
sectors and/or noncompliance problems, particularly key program priorities, with emphasis on
violations that impact areas with environmental justice concerns, and violations that, once
corrected, are likely to result in measurable pollution reductions.
2. Reset Our Relationships with States
Regions are expected to implement EPA's compliance incentive policies
(http://www.epa.gov/compliance/resources/policies/incentives), with the assistance of State,
tribal, and local agencies, to encourage the regulated community to voluntarily discover,
disclose, and correct violations before regulatory agencies identify entities for enforcement
investigation or response.
3. Improve Transparency
EPA will continue to enter data into ICIS regarding the receipt and resolution of self-disclosures
and, at the end of FY2012, EPA will continue to report on the number of self-disclosures
received and resolved together with the environmental outcomes resulting from disclosing
entities correcting their violations.
C. Federal Facilities Enforcement Program Performance Expectations
EPA's compliance and enforcement program involves more than 30,000 federal facilities and
installations spread across nearly 30% of the nation's territory, among which are some 10,000
currently regulated under the Agency's various statutes. As such, it is one of the EPA's largest
and most diverse sectors to oversee. Given limited resources, the primary focus in this sector has
been on monitoring and enforcement, given stewardship opportunities and reliable compliance
assistance offered by others, including at FedCenter, the sector's on-line environmental
stewardship and compliance assistance center sponsored by more than a dozen federal agencies.
Further, while these federal installations are sometimes subject to special provisions of
environmental law, EPA's general practice and policy is to hold them to the same standard of
compliance as private facilities. EPA's federal facilities enforcement and compliance programs
are at http://www.epa.gov/enforcement/federalfacilities/index.html
FFEO, in partnership with other federal agencies, will operate and expand FedCenter as the
central point for federal agency collaboration on greenhouse gas emission response and
compliance with new Executive Order 13514 on federal sustainability.
See http://www.fedcenter.gov/
In an effort to effectively focus limited resources, FFEO and the Regional Federal Facilities
Managers annually negotiate Integrated Strategies as part of the National Federal Facilities
FY2012 OECA NPM Guidance Page 76
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Program Agenda. These integrated strategies align enforcement, compliance, and stewardship
activities and help achieve environmental and health benefits by addressing those problems that
matter to communities. In FY 2012, Regions are expected to continue to implement Integrated
Strategies dealing with storm water, federal underground storage tanks, RCRA corrective action
sites. FFEO and the regions have also identified three exploratory integrated strategy areas for
FY 2012. These new areas focus on enforcement actions at Government Owned/Contractor
Operated/Government Owned/Privately Operated (GOCO/GOPO) facilities, HCFCs/CFCs
enforcement and an energy extraction enforcement initiative which compliments a new national
OECA-wide initiative. In addition, FFEO will complete new inspection targeting capabilities for
vulnerable communities and consider potential new inspection activities associated with the
recently announced initiative dealing with disposal of unneeded federal real estate.
1. Aggressively Go After Pollution Problems That Make a Difference in Communities
Clean water action plan: Regions are expected to continue implementing the Integrated
Strategies on stormwater and underground storage tanks. To support Regions in Assuring clean
drinking water, especially on tribal lands, FFEO will research drinking water pollution and
potential SDWA enforcement particularly at formerly used defense sites (FUDS). Regions and
FFEO are expected to continue to implement an enforcement action against Bureau of Indian
Affairs for violations at schools on BIA and tribal lands. In addition, FFEO will complete new
inspection targeting capabilities for vulnerable communities.
Clean air: To reduce air pollution from largest sources and to support the Regions, FFEO will
complete new research on power plants operating on military bases.
Climate and clean energy: FFEO, in partnership with other federal agencies, will operate and
expand FedCenter as the central point for federal agency collaboration on greenhouse gas
emission response and compliance with new Executive Order 13514 on federal sustainability.
See
In order to protect people from exposure to hazardous chemicals, Regions are expected to sustain
a vigorous inspection and enforcement program at federal facilities. Regions and FFEO are
expected to implement the Integrated Strategy on protecting vulnerable populations.
FFEO will continue research into non-compliance at surface impoundment sites, RCRA
corrective action sites and other RCRA non-TSDF facilities. FFEO will complete new research
on greater compliance/enforcement activity at FUDS. In order to reduce risks from mineral
processing, Regions are expected to address contamination and cleanup at federal abandoned
mine sites. In an effort to reform chemical management enforcement, Regions are expected to
address issues with PCBs in ships and asbestos and pesticides at military sites. FFEO will work
to secure penalty authority against federal facilities through TSCA reauthorization. In addition,
FFEO and Regions are expected to continue implementing the Integrated Strategy on federal
prisons.
FFEO strongly encourages the Regions to take enforcement actions to improve compliance at
federal facilities. For FY 2012, federal facility resources should give first priority to taking
FY2012 OECA NPM Guidance Page 77
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appropriate and timely enforcement actions, as defined within relevant media-specific policies,
for each federal facility inspected as a consequence of Federal Facility Integrated Strategies
efforts. Where appropriate, FFEO advocates including environmental management system
(EMS) improvements and SEPs as part of enforcement action settlements. FFEO also urges the
Regions to take timely and appropriate enforcement actions to address violations of clean up
responsibilities.
Enforcement Follow Up and Projections
At mid-year each Region must project the number of formal (1) federal facility enforcement case
initiations and (2) federal facility settlements for FY 2012. The projections should not include
Records of Decision at federal facility CERCLA sites. Projections can include issuance of
Notices of Determinations regarding self-disclosures by federal facilities. The projections should
be emailed by the Regional Enforcement Division Director to the Director of OECA's Federal
Facility Office at the end of the 2nd fiscal quarter. Since these projections are outside the ACS
system, they are not commitments by the Regions.
Please note the reference at Section V.D on page 61 of this Guidance to OSWER's NPMG which
establishes priorities for EPA's Federal Facilities CERCLA Enforcement program. Clean up at
hazardous sites: Regions and FFEO are expected to work to ensure timely completion of
CERCLA Federal Facility Agreements (FFA). Regions are expected to oversee compliance by
federal agencies under FFAs. Those agreements lay out procedures for resolving disputes.
Regions are expected to use the procedures of the agreements, or other applicable enforcement
authorities (such as imminent and endangerment orders in applicable circumstances), when
Federal facilities are not complying with the terms of the agreements or with other legal
requirements. Additionally, Regions and headquarters offices will work together to get
remaining NPL sites as well as new NPL sites under agreements or other legally-enforceable
agreements.
All federal facility enforcement actions are considered nationally significant and require
consultation with FFEO. FFEO will focus its resources to make these consultations timely and
effective.
Regions are encouraged to target federal facilities as part of National Enforcement Initiative
areas, as well as Regional priorities, national initiatives targeted at geographic areas, EJ areas
and federal facilities Integrated Strategies areas. Under Sections III, IV, and V of this Guidance,
each Region must report the number of federal facilities evaluations, investigations and
inspections included within commitments under the various Regional media program
commitments.
COMMITMENT FED-FAC05: Each Region must conduct ten (10) federal facilities
inspections to support integrated strategy areas, which include stormwater; federal underground
storage tanks, federal prisons; RCRA surface impoundments, RCRA corrective action sites, and
vulnerable populations. These inspections can be achieved through any combination of single
media or multimedia inspections with the following limitations: (1) a maximum of three UST
inspections can count toward this goal and (2) a maximum of three (3) vulnerable community
FY2012 OECA NPM Guidance Page 78
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inspections can count toward this goal, and (3) for any multimedia inspection conducted, it shall
count as two inspections toward this goal if two of the individual inspections support the
Integrated Strategies. These inspections may simultaneously satisfy inspections commitments
required in National Enforcement Initiative or other core program areas.
2. Reset Our Relationships with States
Regions are expected to hold States accountable for responsible federal facility compliance
monitoring and enforcement activity.
3. Improve Transparency
Regions are expected to share environmental information appropriately with the public for
federal facility environmental violations, including through press releases for all enforcement
actions, and at federal facility cleanup sites. EPA will pursue legislative changes to ensure
federal agency environmental accountability under federal laws.
D. State Review Framework (SRF) Expectations
In FY 2012, Regions are asked to support the SRF in the following ways:
Conduct Round 3 SRF reviews on state CAA, CWA, and RCRA enforcement programs,
completing in FY2012 all states that did not receive a review in Round 2, and including 1
pilot state review using an integrated permit and enforcement review process in the 2nd
half of FY2012. Ensure that commitments to implement significant recommendations for
program improvements are captured in appropriate negotiated PPAs, PPGs, or categorical
grant agreements between the Region and the State, with accountability for carrying out
those commitments. SRF review results should be integrated with, and viewed and
discussed with the State in coordination with permit reviews.
Regions should use all available data to benchmark and monitor the enforcement
performance of their States. Data sources include (but are not limited to) federal and
state data systems, permitting and enforcement performance reviews, and other audit or
evaluation reports.
Enter both draft and final SRF reports, which include Preliminary Data Analyses, file
reviews, recommendations, state comments, and benefits arising from Framework
reviews, into the Lotus Notes SRF Tracker database upon completion of a SRF review.
Monitor the progress of States and Tribes in carrying out the recommendations of rounds
1 and 2 of the SRF, and record the progress quarterly in the Lotus Notes SRF Tracker
database.
Use results of reviews to inform annual planning and regular progress meetings with
States. Where progress resolving SRF recommendations are not being made, Regions
should escalate their responses to state performance issues.
COMMITMENT SRF01: Develop a schedule of state reviews for the four years of Round 3
(2012-2016), completing all remaining states from Round 2 in 2012. Included in this 2012 work
is conducting for one state, an integrated permit and enforcement review process. Identify the
FY2012 OECA NPM Guidance Page 79
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number of Round 3 reviews to be conducted, consistent with SRF guidance in FY2012, by year
and by state. Where appropriate, program improvements should be captured in appropriate
negotiated PPAs, PPGs, or categorical grant agreements between the Region and the State, with
accountability for carrying out those commitments. Information on SRF reviews, along with the
recommendations, is to be entered into the SRF Tracker.
SRF guidances, policies, and templates for reporting are found at http://www.epa-
otis.gov/srf/srf tracking.html.
FY2012 OECA NPM Guidance Page 80
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SECTION IX. FY2012 OECA WORKPLAN SUBMISSION INSTRUCTIONS
A. Annual Commitment System
Following the release of the final OECA NPM Guidance, Regions should hold discussions with
States and Tribes to discuss the highest priority work across the Region ands States for the
upcoming year. This work should be an integration of national, regional and state priorities, and
consider permitting and enforcement activities that will lead to improvements in compliance and
in environmental conditions. The Regions and States should discuss how to work together to
ensure that the highest priority work gets done, including consideration of this NPM Guidance,
along with guidance of other EPA programs.
Regions and States should develop draft numbers for the commitments contained in the guidance
that relate to state and tribal activities. Regions should also assess their own resource levels in
relation to the priority work identified in the regional/state discussions and the state and tribal
contributions to that work, and the work outlined in the NPM Guidance.
OECA will hold a planning discussion with each Region at the senior management level during
the spring of 2011 to discuss the strategic allocation of the Region's resources, with the goal of
informing the negotiation of the ACS commitments for the Region for the coming year. OECA
understands that the demands of ensuring compliance with the myriad of environmental laws and
programs covered by this NPM Guidance may exceed a Region's resources, and wants to ensure
that available resources are put towards addressing the most important sources and most serious
violations that affect the environment and public health.
Current schedules call for Regions to enter their draft targets into the annual commitment system
by July 9, 2011. By completing OECA and regional senior management discussions prior to this
time, the process for resolving any issues and finalizing annual regional targets should be
streamlined. During this same time, Regions should engage States and Tribes in negotiations to
complete the grant process (PPAs, PPGs, and Categorical Grants), including translating regional
targets into formal commitments supported by state-by-state agreements. All commitments
should be final by October 22, 2011.
B. FTE Resource Charts
The Regions should complete FTE charts similar to the charts completed in previous planning
cycles. Charts organize FTE information by goal, objective, and sub-objective, and then cross-
walk to the media program elements. The importance of the FTE Resource Charts is significant
due to increased interest from the Office of Management and Budget, the Inspector General, and
Congress. Regions will receive FTE templates in August 2011. It is imperative that Regions
complete these charts and submit these documents to Christopher Knopes and Lisa Raymer on
September 3 0,2011.
2011 Final - Enter the Region's final FTE allocation for FY2011 in the 2011 Final
column.
FY2012 OECA NPM Guidance Page 81
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2012 Proposed - Enter the Region's proposed FTE allocation for FY2011 in the 2012
Proposed column. Headquarters recognizes that FTE levels may change after the Agency
receives the FY2011 enacted budget after October 1, 2012. Therefore this number is a
"best guess" estimate.
FY2012 OECA NPM Guidance Page 82
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SECTION X. LIST OF ACRONYMS
A
ACS - Annual Commitment System
AHERA - Asbestos Hazard and Emergency Response Act
AFS - Air Facilities System
AFS ICR - Air Facilities System - Information Collection Request
AST - Above Ground Storage Tank
ASDWA - Association of State Drinking Water Administrators
B
BIA - Bureau of Indian Affairs
BMP - Best Management Practices
BoP - Bureau of Prisons
C
CA - Compliance Assistance
CAA - Clean Air Act
CAC - Compliance Assistance Coordinator
CACDS - Compliance Assistance Conclusion Data Sheet
CAFO - Concentrated Animal Feeding Operations
CBP - Customs and Border Protection
CBI - Confidential Business Information
CCDS - Case Conclusion Data Sheet
CDC - Centers for Disease Control
CEC - Commission for Environmental Cooperation
CEI - Compliance Evaluation Inspection
CERCLA - Comprehensive Environmental Response, Compensation and
Liability Act
CESQG - Conditionally-exempt Small Quantity Generator
CFC - Chlorofluorocarbon
CID - Criminal Investigation Division
CIPs - Compliance Incentive Programs
CMS - Compliance Monitoring Strategy
CRT - Cathode Ray Tubes
CSOs - Combined Sewer Overflows
CSS - Combined Sewer Systems
CWA-Clean Water Act
D
DARTER - Data on Aquatic Resource Tracking for Effective Regulation
FY2012 OECA NPM Guidance Page 83
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DMR - Discharge Monitoring Report
DOH - Department of Homeland Security
DOJ - Department of Justice
E
EA - Environmental Assessment
EIS - Environmental Impact Statement
EJ - Environmental Justice
EJAC - Environmental Justice Areas of Concern
EJSEAT - Environmental Justice Strategic Enforcement Assessment Tool
EBLLs - Elevated Blood Lead Levels
EMP - Environmental Management Practices
EMR - Environmental Management Reviews
EMS - Environmental Management System
EPA - Environmental Protection Agency
EPCRA - Emergency Planning and Community Right to Know Act
ERPs - Enforcement Response Policies
ERP - Environmental Results Program
ESD - Explanations of Significant Differences
ETT - Enforcement Targeting Tool
F
FCE - Full Compliance Evaluation
FEMA - Federal Emergency Management Agency
FFA - Federal Facility Agreement
FFEO - Federal Facilities Enforcement Office
FIFRA - Federal Insecticide Fungicide and Rodenticide Act
FTE - Full Time Equivalent
FTTS/NCDB - FIFRA-TSCA Tracking System/National Compliance
Database
FRP - Facility Response Plan
FRV - Federally Reportable Violations
FUDS - Formerly Used Defense Sites
FY-Fiscal Year
G
GACT - Generally Available Control Technology
GAO - Government Accounting Office
GHG - Greenhouse Gas
GIS - Geographic Information System
GME - Groundwater Monitoring Evaluation
GOCO -Government Owned/ Contractor Operated
FY2012 OECA NPM Guidance Page 84
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GOPO - Government Owned/Privately Operated
GPRA - Government Performance and Results Act
H
HAP - Hazardous Air Pollutant
HCFC - Hydrochlofluorocarbons
HPV - High Priority Violators
HPPG - High Priority Performance Goal
HQ - Headquarters
HUD - Housing and Urban Development
I
IAC - Innovative Action Council
ICDS - Inspection Conclusion Data Sheet
ICI - Integrated Cleanup Initiative
ICIS - Integrated Compliance Information System
ICIS - NPDES Integrated Compliance Information System - National
Pollutant Discharge Elimination System
ICR - Information Collection Request
IG - Inspector General
INECE - International Network for Environmental Compliance and
Enforcement
IU - Industrial Users
IPOD - ICIS Policy on Demand
L
LBP - Lead-based Paint
LDAR - Leak Detection and Repair
LEA - Local Education Authority
LGEAN - Local Government Environmental Assistance Network
LQG - Large Quantity Generator
LVE - Low Volume Exemptions
M
MACT - Maximum Achievable Control Technology
MDR - Minimum Data Requirements
MITC - Methyl Isothiocyanate
MO A - Memorandum of Agreement
MOU - Memorandum of Understanding
MS4 - Municipal Separate Storm Sewer System
MSGP - Multi-sector General Permit
FY2012 OECA NPM Guidance Page 85
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N
NAAQS - National Ambient Air Quality Standards
NEI - National Enforcement Initiative
NEIC - National Enforcement Investigations Center
NEJAC - National Environmental Justice Advisory Council
NEPA - National Environmental Policy Act
NESCA - National Enforcement Strategy for Corrective Action
NESHAP - National Emissions Standards for Hazardous Air Pollutants
NETI - National Enforcement Training Institute
NOA - Notice of Arrival
NOV - Notice of Violation
NOx - Nitrogen Oxide
NPDES -National Pollutant Discharge Elimination System
NPL - National Priorities List
NPM - National Program Manager
NRC - National Response Center
NRCS - Natural Resource Conservation Services
NSPS - New Source Performance Standards
NSR - New Source Review
NTP - National Training Plan
O
OAM - Operation and Maintenance
OAP - Office of Administration and Policy
OC - Office of Compliance
OCE - Office of Civil Enforcement
OCEFT - Office of Criminal Enforcement, Forensics and Training
OCFO - Office of Chief Financial Officer
OCIR - Office of Congressional and Intergovernmental Relations
OCSPP - Office of Chemical Safety, Pesticides, and Prevention
ODS - Ozone Depleting Substances
OECA- Office of Compliance and Assurance
OEI - Office of Environmental Information
OEJ - Office of Environmental Justice
OF A - Office of Federal Activities
OGD - Office of Grants and Disbarment
OIG - Office of the Inspector General
OMB - Office of Management and Budget
OPA - Oil Pollution Act
OPP - Office of Pesticide Programs
OSHA - Occupational Safety and Health Administration
OSWER - Office of Solid Waste and Emergency Response
OTIS - Online Tracking Information System
FY2012 OECA NPM Guidance Page 86
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p
PBT - Persistent Bio-accumulative Toxics
PCB - Polychlorinated Biphenyls
PCE - Partial Compliance Evaluation
PCS - Permit Compliance System
PEI - Production Establishment Inspections
PFA - Preliminary Financial Assessments
PM10 - Particulate Matter
PMN - Pre-manufacturing Notice
POTW - Publically Operated Treatment Works
PPA - Performance Partnership Agreement
PPG - Performance Partnership Grants
PRE - Pre-renovation Education
PRP - Potentially Responsible Party
PSD - Prevention of Significant Deterioration
PWS - Public Water System
PWSS - Public Water System Supervision
R
RCRA - Resource Conservation Recovery Act
RCRAInfo - Resource Conservation and Recovery Act Information
RECAP - Regional Enforcement and Compliance Assurance Program
RED - Re-registration Eligibility Decision
RI/FS - Remedial Investigations/Feasibility Study
RMP - Risk Management Plan
ROD - Record of Decision
RR+P - Renovation, Repair and Painting
S
SAAP - Special Appropriations Act Projects
SAC - Special Agent-in-Charge
SCAP - Superfund Comprehensive Accomplishment Planning
SDWA - Safe Drinking Water Act
SDWIS/ODS - Safe Drinking Water Information System/ Operational
Data System
SEC - Securities and Exchange Commission
SEE - Senior Environmental Employment
SEP - Supplemental Environmental Project
SIP - State Implementation Plan
SGTM - State Grant Template Measures
SITS - Strategy Implementation Teams
FY2012 OECA NPM Guidance Page 87
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SLAB - Spent Lead Acid Batteries
SLPD - Special Litigation and Projects Division
SNCs - Significant Noncompliance
SNURs - Significant New Use Rules
SOC - Significant Operational Compliance
SO2 - Sulfur Dioxide
SPCC - Spill Prevention Control and Countermeasures
SPEVI - Superfund Program Implementation Manual
SQG - Small Quantity Generator
SRF - State Review Framework
SSO - Sanitary Sewer Overflows
STAG - -State and Tribal Assistance Grant
SWPPP - Stormwater Pollution Prevention Plan
T
TRI - Toxic Release Inventory
TSCA - Toxic Substance Control Act
TSD - Treatment, Storage and Disposal
TSDF - Treatment, Storage and Disposal Facility
TSS - Total Suspended Solids
TVA - Tennessee Valley Authority
U
UIC - Underground Injection Control
UNICOR - trade name of Federal Prison Industries
USCBP - U.S. Customs and Border Protection
UST - Underground Storage Tank
V
VCMA - Volume of Contaminated Media Addressed
VOC - Volatile Organic Compounds
W
WCED - Waste and Chemical Enforcement Division
WPS - Worker Protection Standards
WW - Wet Weather
FY2012 OECA NPM Guidance Page 88
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FY 2012 Annual Commitment System (ACS) Attachment Template
ENVIRONMENTAL PROTECTION AGENCY
OECA
Opt Col
G
/
O
/
s
5
5
5
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5
ACS
Code
TAA04
V^iVtaAJt
CAA06
TAA07
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CWA07
Measure Text
The number of compliance evaluations to be conducted by the regions at majors sources,
80% synthetic minors, and other sources (as appropriate). [Note: Region should break out
evaluation projections by source classification and by compliance monitoring category
(FCE, PCE, and Investigations). In the comment section, each region should also provide
the number of federal facility FCEs, PCEs and investigations. Projected investigations
under this commitment are those investigations initiated by the Regions for the air
enforcement program outside of the National Enforcement Initiatives, and identified by the
air program (e.g., MACT, NSPS).
Ensure that delegated state agencies implement their compliance and enforcement
programs in accordance with the CAA CMS and have negotiated facility -specific CMS
plans in place. The Regions are to provide the number of FCEs at majors and 80%
synthetic minors to be conducted by individual state/local agencies to demonstrate program
implementation consistent with CMS. However, if a delegated agency negotiates with a
Region an alternative CMS plan, this Commitment should reflect the alternative plan.
[Note: Break out evaluation projections (e.g., FCEs; PCEs included in alternative plan) by
source classification]. Prior to approving an alternative plan, Regions should consult with
the Office of Compliance (OC) and provide OC with information on how the state/local
agency compliance monitoring air resources will be redirected and the rationale for making
the change.
The Regions and delegated agencies should enter 100% of MDRs in AFS consistent with
Agency policies, including the 2010 FRY Clarification, and the AFS ICR. The reporting of
such complete, accurate, and timely data by delegated agencies should be reflected in
written, up-to-date agreements with the Regions. If the Region is responsible for entering
data for a delegated agency or Tribe, the Region should identify the delegated agency or
Tribe.
By December 3 1, 201 1, provide a specific NPDES Compliance Monitoring Strategy
Non-
Commi
tment
Indicat
or
(Y/N)
N
N
N
1 N
N
State
Perform
ance
Measure
(Y/N)
N
N
N
1 N
N
Planni
ng
Target
N
N
N
National
Target
(FY2011
Pres.
Bud)
N
N
1 N
N
N
-------
5
\J
5
5
5
5
5
5
TWA 09
\_^ TT .ii \jy
CWA10
SDWA02
k?A/ TT F\.\J A
RCRA01
RCRA01.
s
RCRA03
RCRA02
(CMS) plan for each State in the Region. The plan should provide universe information for
the CMS categories; sub-categories covered by the CMS and combined EPA and State
expected accomplishments for each category and subcategory. The plan should identify
trade-offs made among the categories utilizing the flexibility designed into the CMS policy
to target the most significant sources with potential to impact water quality. At end of year
provide for each State a numerical report on EPA and state inspection plan outputs, by
category and subcategory. To increase the transparency of NPDES inspection data, OECA
will work with Regions and State associations to develop formats for releasing inspection
data on CMS implementation performance on a state-by-state basis.
Regions should submit summaries of the collaborative EPA/State annual work planning
process addressing NPDES permitting, compliance monitoring, and enforcement activities,
including work-sharing, to the Office of Compliance and the Office of Wastewater
Management by October 3 1, 201 1 for FY 2012 activities.
Regions should focus their CWA enforcement work towards meeting the national target of
37% for concluding federal judicial and administrative enforcement actions resulting in a
reduction of pollutants that pertain to facilities discharging into waters that do not achieve
water quality standards. The regions should report their data per the November 2010
guidance issued by OECA, and any subsequent updates issued for FY2012.
During FY 2012, the primacy agency must address with a formal enforcement action or
return to compliance the number of priority systems equal to the number of its PWSs that
have a score of 1 1 or higher on the July 201 1 ETT report.
Project by State, and Indian country where applicable, the number of operating non-
governmental TSDFs, to be inspected by the Region during the year1. Regions must
commit to inspect at least two (2) TSDFs in each State or Indian country unless OECA
approves a deviation from this requirement. For example, deviations are given for states
with small universes where it might not make sense for a Region to inspect two TSDFs per
year. Financial responsibility is an important component of the RCRA core program and
should be included as part of the inspection of each TSDF (although the financial
responsibility reviews do not have to occur at the same time nor be conducted by the same
people who conduct the field inspections).
Project by State the number of operating TSDFs to be inspected by the State during the
year.
Inspect each operating TSDF operated by states, local, or Tribal governments.
Project by State and Indian country, the number of LQGs, including those at federal
N
1 N
N
N
N
N
N
N
N
1 N
N
N
N
N
N
N
N
1 N
N
N
1 N
N
N
N
N
N
1 N
N
N
1 N
N
N
N
N
1 Currently there is only one TSD in Indian country.
-------
5
5
\J
c.
o
5
5
5
5
5
\J
RCRA02.
s
RCRA04
OSRE-04
TSC01
FTFRA-
i1 ii1 ivri
FEDl
EPCRA
01
EPCRA
02
FED-
FAC05
facilities, to be inspected by the Region during the year. Each Region must commit to
inspect at least six (6) LQGs in each State, and 20% of the Region's LQGs universe in
Indian country, unless OECA approves a deviation from this requirement. For example,
deviations are given for states with small universes where it doesn't make sense for a
Region to inspect 6 LQGs per year or 20% of the Region' s LQG universe in Indian
country. In the Comment Section, provide the number of federal facility LQG inspections.
Project by State the number of LQGs to be inspected by the State during the year. At least
20 percent of the LQG universe should be covered by combined federal and State
inspections unless an alternative plan is approved under the RCRA CMS.
Project by State and Indian country the number of financial assurance mechanisms to be
reviewed by the Region during the year. Regions must commit to review financial test
and/or corporate guarantee submissions for compliance with the closure and post-closure
regulations at a number of facilities at least equal to the Region's commitment under
RCRA01. As an alternative, Regions may choose to conduct formal financial record
reviews for facilities that did not have a financial assurance review during the FY 2005-FY
2010 as part of the national enforcement initiative. The financial test/corporate guarantee
compliance evaluations or financial record reviews may occur at the same facilities being
inspected under RCRA01 or at different TSDFs.
For 100% of the financial test submissions received each fiscal year for corrective action
with cost estimates over $5 million, determine whether the submission is in compliance.
Where the submission is noncompliant, take appropriate enforcement action to address
noncompliance (e.g., notice of violation). If possible, return facility to compliance by end
of fiscal year.
Project the number of FY2012 TSCA inspections.
Project regional (federal) FIFRA inspections, including those at federal facilities. Each
Region should conduct a minimum often (10) FIFRA inspections. In the Comment
Section, provide the number of federal facility inspections.
Conduct at least 4 EPCRA 313 data quality inspections.
Conduct at least 20 EPCRA 313 non-reporter inspections.
Each Region must conduct ten (10) federal facilities inspections to support integrated
strategy areas, which include stormwater; federal underground storage tanks, federal
prisons; RCRA surface impoundments, RCRA corrective action sites, and vulnerable
populations. These inspections can be achieved through any combination of single media
or multimedia inspections with the following limitations: (1) a maximum of three UST
inspections can count toward this goal and (2) a maximum of three (3) vulnerable
community inspections can count toward this goal, and (3) for any multimedia inspection
conducted, it shall count as two inspections toward this goal if two of the individual
N
N
N
N
N
N
N
N
1 N
N
N
N
N
N
N
N
N
1 N
N
N
1 N
N
1 N
N
N
N
N
N
1 N
N
N
1 N
N
1 N
N
N
N
N
N
1 N
-------
5
SRF01
inspections support the Integrated Strategies. These inspections may simultaneously
satisfy inspections commitments required in National Enforcement Initiative or other core
program areas.
Develop a schedule of state reviews for the four years of Round 3 (2012-2016), completing
all remaining states from Round 2 in 2012. Included in this 2012 work are conducting for
one state, an integrated permit and enforcement review process. Identify the number of
Round 3 reviews to be conducted, consistent with SRF guidance in FY2012, by year and
by state. Where appropriate, program improvements should be captured in appropriate
negotiated PPAs, PPGs, or categorical grant agreements between the Region and the State,
with accountability for carrying out those commitments. Information on SRF reviews,
along with the recommendations, are to be entered into the SRF Tracker.
N
N
N
N
-------
Appendix 2
Accountability Measures for Enforcement and Compliance Assurance1
1. Environmental and/or public health benefits achieved through concluded enforcement
activities, e.g., case settlements, injunctive relief, etc.
Pilot measure: Volunteer states will be sought to participate with EPA in pilot test
use of Case Conclusion Data Sheet or comparable approaches to analyzing benefits
achieved from enforcement activities.
2. Rates of significant noncompliance for selected regulated populations.
All states continue to provide facility-specific compliance information through
automated data systems. Volunteer states will be sought to participate with EPA in
development of statistically valid compliance rates.
3. Percentage of significant non-compliers (SNCs) that have been returned to compliance
or otherwise addressed.
All states continue to provide facility-specific compliance information through
automated data systems.
4. Results of using State alternative compliance approaches (e.g., audit laws or policies, sm all
business compliance policies, XL projects) and compliance assistance.
Pilot measure: Volunteer states will be sought to provide EPA with data on
evaluation of the results of compliance incentives and compliance assistance efforts.
Provide narrative description of alternative compliance approaches.
5. Total number of inspections conducted at major facilities, and the percent of total universe
of regulated sources inspected in negotiated priority areas (e.g., industry sectors,
geographic areas).
All states continue to report facility-specific data through automated data systems.
Negotiate means for reporting information on inspections of facilities not covered by
current data systems.
6. Enforcement actions (e.g., case referrals, orders, notices) taken, by media.
All states continue to provide facility-specific compliance information through
automated data systems.
1 As stated in the 1997 Joint Statement on Measuring Progress under NEPPS, "Beyond core performance
measures, there are other program output and fiscal reporting requirements we must use to document our
various program activities." States are expectedto continue reporting this routine program and fiscaltracking
information. At the same time, States and EPA Regions are encouraged to work together to review the value
and cost of these data exchanges and eliminate low-priority reporting.
-------
7. Number of facilities/entities reached through each type of compliance assistance activity.
Pilot measure: Volunteer states will be sought to participate with EPA in pilot to
provide data on compliance assistance activities. Describe any current reporting a
pilot State does on compliance assistance activities.
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Enforcement and Compliance
Data Quality Strategy
March 25, 2002
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TABLE OF CONTENTS
I. Introduction 1
Relationship to Quality Management Plans 1
II. Vision Statement 2
IE. Common Data Quality Issues 3
IV. Data Quality Activities 4
A. Periodic Activities 4
Identifying Data Errors 6
Prioritizing Data Problems Found 6
Selecting Data Quality Projects and Involving the Regions and States 7
Sending Analyses of Problems to Regions and States for Correction 7
B. Ongoing Activities 8
Internet Error Correction 8
Promoting Accuracy of Reports, Paper Records, and Data Entry and Validation
Procedures 8
Updating Data System Guidance 9
System Updates and ICIS/Modernization 10
V. Regional and State Implementation of the Strategy 10
Coordinating with Other Key Activities 10
VT. Conclusion 11
Appendix 1: The Data Quality Strategy and the Office of Compliance
Quality Management Plan 12
Appendix 2: Process for Developing the Enforcement and Compliance Data Quality Strategy
and the FY02 Data Quality Strategy Implementation Plan 13
Appendix 3: Overview Chart of the FY02 Data Quality Strategy Implementation Plan 16
Appendix 4: Description and Schedule for Implementing FY02 Projects 17
A. Random Audits 17
B. Comparative Analyses 18
C. Fields Clarification 19
D. Data Quality Alerts 20
Schedule For FY02 DQ Strategy Implementation Projects 21
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
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Appendix 5: Schedule for Implementing FY03 DQ Strategy Projects 23
Appendix 6: Examples of Existing Policies and Procedures for Minimizing Data Errors
Prior to Data Entry for Our Legacy Data Bases 25
A. Region 3 25
B. Region 6 26
C. Region 7 26
D. Region 9 27
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
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I. Introduction
The Enforcement and Compliance Data Quality Strategy's purpose is to develop and implement
an ambitious, practical plan to assess and manage the quality of enforcement and compliance
data. This work is critical for EPA's own business needs throughout OECA and the Regions, for
programs in state and local governments, and for the public. A short but not exhaustive list of
reasons the Agency invests in maintaining the integrity of enforcement and compliance data
includes the following:
> High quality data in EPA's national databases is essential for credible measures, reports,
and analyses.
* EPA managers and members of Congress rely on this data to hold EPA programs
accountable and to inform their decision-making.
* Accurate data, in an accessible and usable form, is essential to support Agency planning
and targeting.
> The Government Performance and Results Act (GPRA) requires federal agencies to
develop program plans and performance measures, and to report on progress achieved
each year. Documenting performance requires timely, high quality data.
> Accurate and complete information in EPA's enforcement and compliance databases
ensures that states are properly credited for their enforcement and compliance monitoring
activities.
* Proof of high quality gives rise to confidence among the public, industry, and other users
of enforcement and compliance data, especially if the public is provided Internet access.
> Conclusions drawn in analyses and reports by OECA or outside groups using EPA data
have been challenged based on concerns about data quality. In recent years, Inspector
General reports have stressed the need for increased attention to data quality in Agency
efforts to monitor and measure enforcement and compliance programs.
Relationship to Quality Management Plans
Although Region's have their own Quality Management Plans (QMP) to ensure data quality, this
Enforcement and Compliance Data Quality Strategy covers areas not traditionally covered by
Regional QMPs. This fiscal year, OC is also updating its Office-level Quality Management Plan
(QMP), which is intended to clearly and fully document the policies, work processes, resources,
management structure, and other critical elements of OC's data quality program. For more
information on the relationship between this Data Quality Strategy and the OC QMP, please see
Appendix 1.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 1 of 27
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II. Vision Statement
The vision of the Data Quality Strategy (DQS) for enforcement and compliance data is to assure
that the data used to support enforcement program decisions are of high quality and accurately
reflect the activity and accomplishments of OECA programs. High quality data is defined as
accurate, complete, and timely data that are clearly presented and consistent with national data
standards. OC believes that assessments of data quality will demonstrate and result in improved
accuracy of enforcement and compliance. The Agency can confidently disseminate and use this
information to evaluate programs, target resources and to inform Congress, the public, and the
news media.
The DQS calls for all levels of OC and its partners to actively manage the quality of data in the
national data systems to the highest possible standards by:
* assessing the quality of enforcement and compliance data in its data systems on an
ongoing basis;
* identifying any missing, incorrect, or inadequate data; and
* responding to problems as they are identified thereby continually improving data that
does not meet data system, program, Office or Agency standards.
The Strategy is designed to reshape ad hoc data quality efforts and to establish routine and
systematic methods for improving and maintaining a high level of data quality. The focus of this
strategy will be to identify data quality problems by examining enforcement and compliance data
in Agency systems and raising issues to the appropriate personnel for further analysis and
correction. When data quality problems are found to be due to the inherent structure of a
database or to established data processing procedures, these issues will be raised both to the
appropriate system managers and to the Integrated Compliance Information System (ICIS)
modernization team, who can act on many of the recommended improvements in
software/hardware specifications, as well as data entry, verification, and documentation.
The following principles will guide implementation of the strategy:
> Research into problems and analyses will focus on real data and its usage.
* Critical analyses will be objective. Analytical techniques that yield comprehensive
assessments, such as random sampling of entire data systems, will be used rather than
anecdotal investigations. Where practical, root cause analyses will be undertaken to
identify systemic reasons for inadequate data quality, which will help formulate practical
solutions.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 2 of 27
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Responsibilities for finding solutions to data quality problems will be clear. Expectations
for performance will be established.
Implementation options to improve data quality will be realistic and feasible. In some
cases, FY02 data quality assessments may examine a longer time period, but
implementation options will be limited to remedying only the two most recent years of
data.
I. Common Data Quality Issues
The data quality activities discussed in this Strategy are specifically aimed at identifying data that
is missing, incorrect, or inadequate. Definitions of these terms are provided below.
Missing Data refer to required files, records or values that are not in the EPA national databases
due to incomplete reporting by EPA Headquarters, EPA Region, a state agency, a local authority,
or facility. This deficiency precludes accurate program evaluations and could suggest that
important environmental work is not being done.
Incorrect Data are values within a field that do not accurately represent the true value. There are
three main reasons for data in a required field to be incorrect. These reasons are data creation
errors, data entry errors, and ambiguity in use of data fields.
Data Creation Errors: Programmatic staff can err while filling out forms that are
forwarded to data entry staff or when entering data online. Some of these errors can be
the result of ambiguity in guidance (see below), poorly designed data reporting tools,
overlapping systems requiring a staffer to report the same data for entry into two or more
systems, and lack of management emphasis on the importance of submitting complete,
high quality data. Facilities may also generate errors in preparing required reporting (e.g.,
monthly discharge monitoring reports required by CWA permits).
Data Entry Errors: Mistakes may be made during data entry by data entry staff or, more
rarely, by translator programs. Mistakes may also be due to a lack of data quality checks
prior to data entry. For example, established procedures to verify the information on
paper records (e.g., inspection reports, enforcement action reports, Case Conclusion Data
Sheets) may be inadequate. Finally, there may not be sufficient training and tools
provided to staff who enter data to ensure data are entered properly.
Ambiguity in Use of Data Fields: Misinterpretations and/or inadequate guidance
concerning what data should be in required fields may result in inconsistency in values
across Regions and states and others.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 3 of 27
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Inadequate Data are defined as records or fields that are not accessible or usable as currently
maintained in EPA national databases. For example, data fields might exist in systems, but EPA
does not require reporting or has allowed the fields to fall into disuse. Alternatively, new data
needs may have arisen due to programmatic changes and the data systems were not modified to
meet those needs. In other instances, inadequate data may result if regulations or policies have
not been updated to match new goals, technologies, or systems.
IV. Data Quality Activities
This Data Quality Strategy proposes various activities to identify and correct current data quality
problems. Annually, OC will develop an enforcement and compliance Data Quality Strategy
Implementation Plan in consultation with Regions and states. The goal of the plan will be to
identify specific data quality issues through periodic activities, such as audits and analyses. The
outcome of these activities will be used to prioritize the order in which to address any data
problems. Resulting analyses will be sent to Regions and states for review and correction where
appropriate. Ongoing activities, such as the development of online correction, will be
undertaken at the same time to address data quality problems that are long-term projects or may
require activities on repeating schedules (e.g., training).
Proposed activities are organized and described in this section according to whether they are
periodic or on-going. Figure 2 shows how the activities fit within the DQS and how they are
expected to complement each other.
A. Periodic Activities
OC will develop an annual Data Quality Strategy Implementation Plan in consultation with the
Regions and states. The plan will identify specific projects for the coming year. It will include
relevant details and planning information for:
> identifying data errors;
> prioritizing problems found;
* selecting data quality projects and involving Regions and states; and
> sending analyses of problems to Regions and states for correction.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 4 of 27
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Figure 2: Activities Established by the Data Quality Strategy
;
I Periodic Activities:
Random
Audits
Periodic
Comparative
Analyses
Analyses of
Discrepancies
in the Use of Fields
Expert Nominated
Problems
Process
for
Prioritizing
Problems
Found
|
>,
Analyses
of Problems
Sent to
Regions/
States
for
Correction
[Ongoing Activities*
I ^^^^^^^^H^^^^^^^^^^^^^^^^^^^H
I Internet error correction
i
! Developing, revising, and maintaining:
| training and tools for data entry clerks
| data entry and validation procedures
| policies and procedures to ensure the accuracy of the
| information on paper records
| Clarification of guidance on fields and new program guidance
I
| ICIS/Modernization efforts and changes to legacy systems
*Any of these ongoing activities may uncover problems that need to be addressed more formally. In
addition, the solutions for some of the prioritized problems may result in revisions or new data entry
procedures, clarification of guidance, or system changes/modernization.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 5 of 27
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Identifying Data Errors
Data problems will be identified through methods such as: random data audits; comparative
analyses; analyses of discrepancies in the use of fields; and expert nominated problems. Each of
these is described below.
> Random Data Audits. Data in selected key data fields will be independently evaluated
through random data audits to validate its accuracy and completeness.
> Periodic Comparative Analyses. Periodically, comparative analyses of particular data
fields across organizational units with delegated authority will be conducted to identify
potential data quality problems. For example, comparing Significant Non-Compliance or
inspection rates within Regions or states to the national average can be used to identify
extreme outlying values that might indicate data problems.
* Analyses of Discrepancies in the Use of Fields. OC will analyze key enforcement and
compliance activity data fields to determine if there are discrepancies in Regional or state
usage. Discrepancies found will be documented, and guidance developed to assist
program implementers and database users in how to use the codes for nationally
consistent reporting.
* Expert Nominated Problems. Staff with significant experience and expertise with
individual data systems (data system staff, program staff or expert users) will identify any
quality issues they encounter. It is expected that such data quality problems will be
identified from intensive usage, such as targeting and measures analyses. In addition,
data problems found by comparing data required to be entered into more than one
database can be used to reconcile information across data systems.
Prioritizing Data Problems Found
Once data problems are identified, they will be prioritized by a standing data quality workgroup
that will consult with relevant stakeholders. Data quality efforts will focus on:
data in the legacy database that will next be modernized;
administrative priorities of stakeholder agencies and offices involved in management of
each data system;
EPA administration priorities;
areas of concern raised by the Environmental Council of the States (ECOS), the Inspector
General, EPA Management, Regional information users and managers;
areas of concern discovered by methodologies for identifying data problems (see Figure
2, 'Periodic Activities');
areas of concern raised by public access; and
Regional and state review of assessments that confirm validity of the problems.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 6 of 27
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Selecting Data Quality Projects and Involving the Regions and States
Development of the annual Data Quality Strategy Implementation Plan will follow a structured
decision making process. This process will resemble the one used for development of the FY02
Implementation Plan (Appendix 2) and is described below. Each year, OECA's MOA Guidance
will specify the number of national data quality projects for EPA and states to work on during
each year.
The process will start with an annual Data Quality Strategy workshop held in the spring.
Participants will include staff from headquarters, Regions and state representatives. Workshop
participants will:
discuss issues related to the identification and implementation of the current year's
projects; and
brainstorm ideas for the next year's projects.
Sub-workgroups will be convened to build upon the discussions from the Data Quality Strategy
workshop and to flesh out the projects to be recommended for implementation as well as
methods for analyzing them. During the summer, the sub-workgroups will make their
recommendations, which will then be sent to the entire Data Quality Strategy workgroup for
review and comment.
The detailed implementation plan for the upcoming year will then be drafted and distributed to a
wider set of stakeholders. This implementation strategy will be distributed for review and
comment to the entire data steward community, including ECOS, before being finalized.
Information on planning, assignment of responsibilities, progress, and results will be coordinated
with Regions and states, via the Regions. State and Regions will have scheduled opportunities to
communicate their comments on the projects to Headquarters.
Sending Analyses of Problems to Regions and States for Correction
Once the data quality problems are identified via Periodic Comparative Analyses, Analyses of
Discrepancies in the Use of Fields, and Expert Nominated Problems and assessments are
complete, and problems are researched and well documented, Regions and states will be
informed of the problems through distribution of analysis reports in various formats (e.g., short
DQ alerts, longer memoranda). These reports will describe in detail an identified data quality
problem narratively, and, where applicable, graphically and quantitatively. They will be written
for the selected problems and sent to the responsible Regions, states (via the Regions), and
Headquarters personnel to alert them of potential data problem so they can correct the data
already in the system and make any other changes needed to avoid the problems in the future.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 7 of 27
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B. Ongoing Activities
The following activities will be undertaken on an ongoing basis to uncover, prioritize and
address data quality problems:
* Internet error correction;
> promoting accuracy of initial reporting, paper records, data entry, and validation
procedures;
> updating a variety of guidance documents for activities that affect data quality; and
* updating data system documentation and support system modernization and ICIS
development.
Many of these activities will be influenced by and will influence the periodic activities described
in the previous section (see Figure 2). For example, data errors identified through periodic
audits and analyses may spur changes to ongoing data quality work (e.g., revisions to data entry
procedures, clarification of guidance, or system changes/modernization). In turn, the ongoing
data quality activities will directly impact the types and number of data quality concerns.
Internet Error Correction
Currently available Internet error correction tools will be applied to particular records in need of
correction. For example, OC will use information from the Headquarters, Regional, and state
data steward networks, as well as the (Online Tracking Information System) OTIS site (and the
Public Access Internet site when it becomes available) and its error correction process to pin-
point data records within OC's national databases in need of correction. The Office of
Environmental Information (OEI) is expected to improve the online system for informing data
stewards at the Regional and state level about potential problems with individual records
reported by data system users. OKI's system will also track the performance of Regional and
state data stewards responsible for making corrections. Resources and encouragement from
program management will be critical to ensure the continued and effective involvement of those
data stewards responsible for responding to error correction requests.
Promoting Accuracy of Reports, Paper Records, and Data Entry and Validation Procedures
Regions and states are expected to commit resources to enter required data into EPA's national
databases in a timely and accurate manner. The following are examples of activities OC may
undertake, or encourage the Regions and states to undertake, to ensure that data quality
procedures are accurately documented and followed.
> Utilize and document existing edit and validation checks in the legacy databases, and
make recommendations for new edit and validation checks to be incorporated into ICIS as
the databases are modernized. As part of OC's Quality Management Plan (discussed in
the Appendix 1), Data System Quality Assurance Plans will be developed for the each of
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 8 of 27
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the data systems for which OC has primary responsibility. The Data System Quality
Assurance Plans will describe the existing and planned editing checks and validation
procedures that are part of each data systems.
* Develop new policies and procedures to minimize data errors stemming from the filling
in of field reports and paper records (e.g., inspection reports, enforcement action reports,
case conclusion data sheets). Distribute these procedures to the staff responsible for entry.
This may include procedures for tracking documents and standardizing document storage.
Some examples of existing database policies and procedures for minimizing data errors
prior to data entry are listed in Appendix 6.
> Provide training for all staff generating and entering data that ultimately resides in EPA's
data systems. Policies and procedures may need to be reviewed for delegated programs
directly entering data into EPA's national databases as well as for states using translator
programs.
> Where the training of data entry personnel is adequate, review the rejected transactions
for a specific period of time. In some cases, the data problems may be due to a "process"
rather than data entry errors. For instance, duplicate discharge monitoring reports
(DMRs) for the NPDES program may be continuously routed for data entry, causing
numerous "record on file" rejects.
> Inform Regional and national program management of the need for sufficient resources to
support the implementation of more comprehensive and accurate data entry and
verification procedures. Please refer to Appendix 6 for examples of existing policies and
procedures for minimizing data errors. For example, disinvestment in accurate, complete
data entry and correction for NPDES minors in the Permit Compliance System has eroded
the quality of enforcement and compliance data for this universe of over 87,800 facilities.
> Conduct a one-time review of instructions for data submission to ensure that Regions and
states provide data in formats consistent with data system requirements (e.g., values
and/or formats should be consistent with data system or translatable with full
documentation).
Updating Data System Guidance
Data system guidance and documentation will be updated to address discrepancies in the use of
key enforcement and compliance activity database fields. Fields that are inconsistently used by
Regions and states could stem from different understandings of how database fields are to be
used, or from outdated media-specific program guidance.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 9 of 27
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System Updates and ICIS/Modernization
OC will work to maintain current, well documented system data dictionaries for those systems
run by OC. Such efforts to create and maintain all required documentation will be explicitly
called for as part of OC's Quality Management Plan. These data dictionaries should provide
clear definitions of data fields and, when necessary, clear definitions of programmatic terms,
such as, what a "final judicial order" means for the RCRA program.
OC will also work with the modernization team to ensure that the data quality improvements
recommended by the Data Quality Strategy are built into the modernized data systems.
V. Regional and State Implementation of the Strategy
Since Regions and states are responsible for entry of enforcement and compliance information,
their active participation in data quality efforts is critical. OECA's Memorandum of Agreement
Guidance will continue to specify the Region's level of commitment to implementing the DQS.
OC will propose the following efforts to ensure Regions and states implement the activities of
this Data Quality Strategy:
* Provide yearly quality assurance awards to states.
> Do not give credit for program actions and results that are not entered in a national
database. Notify programs, Regions and state staff and management of this policy.
> Make any OECA discretionary extramural funding given to states dependent on whether
the state commits to and prioritizes maintaining quality data. Maintaining quality data
includes providing the data in a form consistent with EPA data system requirements and
codes.
Coordinating with Other Key Activities
The proposed data quality planning, implementation, and assessments will be coordinated with
other activities to further encourage state and Regional participation in data quality efforts.
These activities are listed below.
> Highlight data quality issues in the Regional profiles that are provided to senior
management.
* Expand program status review reports to include additional data quality information.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 10 of 27
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Publish data quality statistics for Regions to promote positive peer pressure.
Communicate findings related to database design issues that affect data quality to the
ICIS team.
Raise data quality issues through the Enforcement and Compliance Performance Board.
Provide annual expectations for data quality goals and/or participation in data quality
activities in MO As.
Emphasize data quality in National Environmental Performance Partnerships (NEPPS)
and grant guidances.
VI. Conclusion
In FY2001, the Office of Compliance began developing this Data Quality Strategy (DQS) for
assessing and actively managing the quality of enforcement and compliance information. The
DQS sets forth the National Enforcement and Compliance Program's vision for assuring that the
data used to support enforcement program decisions are sound and accurately reflect the
activities and accomplishments of the program. The DQS also calls for a variety of data quality
assessments of EPA data systems which will be undertaken in FY2002 and subsequent years.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 11 of 27
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Appendix 1
The Data Quality Strategy and the Office of Compliance Quality Management Plan
The updated OC Office-level Quality Management Plan (QMP) will detail how components of
the DQS, such as data quality assessments, will inform ongoing planning and implementation of
data quality activities and data system management. Figure 1 shows an outline of the major
sections in OC's Quality Management Plan and how portions of the Strategy will fit within it.
Figure 1: How the Data Quality Strategy Fits Within OC's Quality Management Plan
Quality Management Plan
Management and Organization of OC
(Include DQS Introduction, Vision Statement, Description of
OC's Data Quality Workgroup)
Quality System Components
(Include DQS Activities and Data Quality Strategy
Implementation Plan)
Personnel Qualifications and Training
Procurement of Items and Services
Documents and Records
Computer Hardware and Software
Planning
Implementation of Work Processes
Assessment and Response
(Include DQS Random Audit of Inspection Data, Comparative
Analyses, Analyses of Discrepancies in the Use of Compliance
and Enforcement Data Fields, Data Quality Alerts)
Quality Improvement
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 12 of 27
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Appendix 2
Process for Developing the Enforcement and Compliance Data Quality Strategy and the
FY02 Data Quality Strategy Implementation Plan
On May 21, 2001 a call memorandum was sent from Michael Stahl asking for workgroup
members to develop a Data Quality Strategy for Enforcement and Compliance Data.
Representatives from the media program offices and staff who work directly with EPA
maintained enforcement and compliance national databases (DOCKET, AFS, PCS, RCRAInfo,
FTTS, and SDWIS) signed up for the workgroup as well as Headquarter personnel (particularly
those involved with measures, targeting, and data system management).
On June 20, 2001, a Data Quality Strategy workshop was held in Washington. This served as
the first workgroup meeting. There were presentations at the workshop on:
* an overview document providing a vision statement, definitions, and an initial outline of
the Data Quality Strategy,
> methodologies for identifying, validating, and correcting of data problems and Errors;
* data errors on the front end; and
* documentation, guidance, and modernization - their impact on data quality.
In addition, we had brainstorming sessions in the afternoon. Discussions included:
> various options for conducting the identification and correction of errors;
* coming up with a list of problems we know about in terms of data entry;
* coming up with a list of policies and procedures for entering data; and
> coming of with lists of database fields needing clarification.
On June 28, 2001 summaries of the three breakout sessions were sent to the entire Data Quality
Strategy workgroup. On July 6, 2001, the next version of the vision statement, definitions, and
outline of the Data Quality Strategy was sent to the workgroup for comment along with
documents which grouped the information from the three June 20 workshop breakout sessions
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 13 of 27
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into categories and tasks. We asked workgroup members to get back to us with comments on
these documents and the tasks they preferred to work on.
From these responses two sub-workgroups were created:
1) Tasks on Methodologies for Identification of Data Problems and Correcting Errors
(led by David Sprague)
2) Tasks on Potential Fields Needing Clarification: Know Areas where Potential Misuse
or Inconsistent Use is Occurring (led by Lynn Vendinello)
We also sent a list of overall, cross-cutting tasks for which we requested input from as many as
people as possible.
We did not initiate a sub-workgroup on Data Quality on the Front End. We asked the data
system managers to provide us with write-ups describing what data entry and validation checks
are already programmed into our national databases. On June 18, 2001, we requested the Data
Quality Strategy workgroup members provide us with information on policies and procedures
their Regions and states have to ensure the accuracy of the information on the paper records
(e.g., inspection reports, enforcement action reports, case conclusion data sheets) before they are
transmitted to data entry staff. We also requested information on what training and tools are
provided to staff who enter data to ensure the data will be entered accurately.
The number of data quality projects which are being recommended for FY02 were decided upon
by the data quality and targeting teams of the Information Utilization & Targeting Branch
(IUTB), and OC management consensus. The sub-workgroups and the data quality and targeting
teams of IUTB recommended projects. Appendix 3 provides an overview of the data quality
projects planned for implementation in FY02. Appendix 4 describes the projects in more detail
and presents a schedule for implementation. Appendix 5 presents a schedule for FY03 projects.
The Potential Fields Needing Clarification sub-workgroup helped decide which fields will be
analyzed and how the analyses will be done. The Identification of Data Problems and Correcting
Errors sub-workgroup helped develop the Random Audit of Inspection Data project as well as
the Comparative Analyses charts. The decisions made by these sub-workgroups were made with
consultation from the data quality and targeting teams of the Information Utilization & Targeting
Branch (IUTB). In addition, the targeting team of IUTB nominated two data quality alerts to be
sent to the user communities early in 2002.
The next step in the review process was to send the recommended data quality projects and
analyses to the entire Data Quality Strategy workgroup for review and comment. For example,
the entire Data Quality Strategy workgroup were sent:
1) the proposals for how to analyze the four codes needing clarification,
2) the proposed methodology for conducting the random audit of inspection data,
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 14 of 27
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3) sample periodic comparative analyses charts,
4) two data quality alerts proposed by the targeting team of IUTB.
Since the Data Quality Strategy workgroup is composed of headquarters and Regional database
and program representatives, as well as one state representative, their input was essential.
Once the comments by the Data Quality Strategy workgroup were received, the FY02 Data
Quality Implementation Plan was completed. This plan provides detailed outlines of all the data
quality projects which will be conducted in 2002. Before finalizing the plan, the Implementation
Plan was sent to all the affected user communities, including ECOS, for their review and input.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 15 of 27
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Appendix 3
Overview Chart of the FY02 Data Quality Strategy Implementation Plan
DQ Activity
Random Audits
Comparative Analyses
Fields Clarifications
Data Quality Alerts
Level of Activity
One per year
Analyses of 4
indicators, three media
projects issued semi-
annually
New fields are to be
analyzed each year
2 issued annually
Current Proposed
Project
Inspection Fields of
AFS, PCS, and
RCRAInfo
Inspection Coverage,
formal enforcement
actions, penalties and
SNC data in AFS, PCS,
and RCRAInfo
PCS Enforcement
Action Codes
4 RCRA fields
One Air: One RCRA
Correction/
Identification
Method Proposed
Select permits/facility
ID's randomly. Post
inspection data from
national data systems
for those ID's on
website.
State level values
compared against
national averages
Investigate current
usage of data fields and
bring findings back to
workgroup
Discoveries currently
being brought to
workgroup attention.
Regional Involvement
Compare paper records
to posted data on
website. States/Regions
can indicate
discrepancies online.
Follow-up with states
that show low outlier
values (e.g., less than
half the national ave.).
Workgroup established
to develop responses for
each field needing
clarification.
Clean up data as
indicated
State Involvement
Compare paper records
to posted data on WEB
site. Indicate
corrections
States with low outlier
values will have to
certify validity of data
or explain problem.
Workgroup established
to develop responses for
each field needing
clarification.
Clean up data as
indicated
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 16 of 27
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Appendix 4
Description and Schedule for Implementing FY02 Projects
The following Appendix describes the projects that OC plans to implement during FY02. An
implementation schedule for FY02 projects is presented at the end of this appendix. For further
information on any of these projects, please contact David Sprague (sprague.david@epa.gov).
A. Random Audits
Objective: To quantify the accuracy and completeness of selected fields as maintained in
the federal data systems.
Example of the type of statements that will be supported by the audit results: "The inspection
information maintained by EPA is 95% accurate. Based on the survey methodology used, we
are 95% confident that this error rate is within 3% of the true value."
* This year's audit will examine inspection data only.
* The audit will focus separately on populations within each of the three media databases:
/ Facilities subject to CAA programs as defined by the RECAP universe = 42,075
ป/" Facilities with active, major water permits = 6,670
/ Facilities defined as TSDs and LQGs in RCRAInfo = 23,046
* An audit of 8 facilities per program and state is designed to minimize respondent burden
for the Regions and states and will yield statistically valid results with which to
characterize accuracy of inspection information in the national data systems.
> Reviewing this number of facilities should provide a large enough sample size to have
95% confidence in the results, with an error rate of+/- 3%.
Random Audits: Comments and Responses
The following comments were made by states and Regional staff on earlier drafts of the audit
methodology:
* Comment: The universe of facilities sampled should include more facilities from larger
states and less from smaller states.
Response: In developing the random audit, OC was sensitive to not overburdening
individual states. The sample size of eight is based on the number of permit IDs
necessary from the largest states (in terms of federally reportable inspections) to obtain
results that allow EPA to be 95 % confident that the results are within a reasonably small
confidence interval. The sample size of eight does lead to over sampling from smaller
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 17 of 27
-------
states. This over sampling of some states should provide a cushion by helping to address
the possibility that some states will not fully participate. Statistical weighting of the audit
results will adjust for over sampling in some smaller states.
* Comment: States should be able to check the hard copy data against their state/local data
system at the same time they check the data on the proposed Data Quality Website.
Response: Others in the workgroup believe that it is not always the same person who
would check the hard copy and the state/local data systems. To reduce confusion and
workload, OC feels that it is appropriate to keep the focus of the random audit on
checking discrepancies in the federal data systems. A follow-up request to check
state/local data system will be made only if discrepancies are found.
> Comment: States will need notification regarding this effort during the once a year
EPA/state MOA or PPG negotiations.
Response: This is a relatively small effort and is directly related to compliance with the
Data Quality Strategy. As such, it should be considered as included in the previously
negotiated MO As. In developing the random audit, EPA was sensitive to not
overburdening individual states. In any given state program, checking eight records is not
expected to be a significant burden.
B. Comparative Analyses
Objective: To identify potential data quality problems (outliers) by comparing state-level
statistics to an established benchmark (i.e., 1A national average).
The following activities are proposed for FY02:
* Comparative analyses charts for RCRA, CWA, and CAA which show all the states sorted
by percentages and will include:
/ Inspection coverage
/ Ratio of formal enforcement actions to number of facilities inspected
/ Ratio of HPV/SNC facilities per facilities in violation
> The Regions overseeing states that fall below a performance threshold (i.e., one-half the
national average) would be sent a memorandum asking them to
/ discuss the findings of the comparative analyses;
S certify data is accurate; and
S determine cause for missing data.
* Comparative Analyses: Comments and Responses
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 18 of 27
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Comments by members of the Workgroup included:
* Comment: For air, comparative charts of enforcement actions/total # facilities and
HPVs/total # facilities make more sense than having # of inspections and # violations as
the denominators.
Response: Using the number of inspections in the denominator is an appropriate
measure of data quality, rather than using the number of facilities. This approach to the
data quality assessment of actions takes into account two factors that are expected to be
related to the reported number of actions: 1) the number of facilities and 2) the number of
inspections (the amount of effort put forth by the program). The same logic applies to
the SNC analysis. That is, disregarding the level of effort put forth by the program will
change the results and highlight states that do not have many facilities in violation.
> Comment: It would be good to coordinate these analyses with the annual audits Regions
conduct of states regarding specific facilities.
Response: The Regions are encouraged, as much as possible, to coordinate the concerns
raised by these analyses with their audits of their States.
C. Fields Clarification
Objective: Identify discrepancies in the use of key enforcement and compliance data fields.
* RCRA Fields Clarification: The workgroup of Regional and Headquarters members have
participated in a series of conference calls to identify the appropriate use and definition
of informal vs formal action codes, and the applicability of corrective action codes as
they pertain to the enforcement program. The group has received input from the RCRA
and Corrective Action enforcement program offices indicating the appropriate use of
existing codes to address enforcement and/or corrective action remediation. A guidance
package is being developed and will include specific scenarios to assist program
implementers in determining how to use the codes for nationally consistent reporting.
Completion of the draft guidance package is expected by mid-March, 2002.
* Four RCRAInfo codes were examined:
i/" RCRA New Violation or Roll-Over of Existing Violations,
/ Appropriate Entry of Formal and Informal Actions,
/ RCRA 500 vs. 600 Series,
S Corrective Action Codes in the Enforcement Module.
* In addition, a DQ sub-workgroup identified one PCS code for study:
/ Compliance Schedule Event Codes
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 19 of 27
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Fields Clarification: Schedule
* Donna Inman is working on the necessary guidance and clean-up related to the 4 RCRA
codes studied.
* The PCS Enforcement Action Clean-up guidance will be distributed in final soon.
* A workgroup has not begun yet to work on clean-up of the compliance event schedule
codes in PCS.
D. Data Quality Alerts
Objective: Address data quality problems identified by data users (e.g. targeting,
measures, and Regional analysis)
* Two Data Quality alerts have been chosen:
i/" HPV facilities being entered into AFS without any underlying violations being
entered into the system.
S Regions and States failing to close out violations in RCRAinfo
* Two more data quality alerts will be written and distributed later in the year
Data Quality Alerts: Comments and Responses
> Comment: Some reviewers misunderstand the concept of a Data Quality Alert.
Response: Language will be added to the Data Quality Alerts describing their purpose
and what responses are expected from the Regions and States.
> Comment: Manual updating of the HPV flag is no longer necessary. The excerpt from
Appendix A of the T&A HPV Workbook does not reflect this.
Response: Clarifying language will be added to the CAA data quality alert to respond to
these concerns.
* Comment: Facilities could have come into compliance more than 2 years ago but still
have HPV status since not all penalties have been paid yet. This effort may prove to be a
lot of work with little return if the data is found to be valid for many facilities.
Response: Clarifying language will be added to the CAA data quality alert to respond to
these concerns.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 20 of 27
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Appendix 4: Schedule for FY02 DQ Strategy Implementation Projects (Page 1 of 2)
* = Will happen within specified week
| | = Will happen over specified weeks
= Will happen sometime during
specified time period
Week of
Data review prior to
public access announced
Data review for public
access site
Release of public access
site
FY02 Audit instructions
sent out
State and Regional audit
of sampled inspection
records
Distribute, and
Regional/State review of
FY02 Audit preliminary
results
Comments on FY02 Audit
prelim results due
Distribute FY02 Audit
final results
Clean-up of RCRA fields
2/18
2/25
3/4
3/11
3/18
ป
3/25
4/1
4/8
4/15
4/22
4/29
5/6
5/13
5/20
5/27
1 1
1 1
ป
I i
1 1
1 1
1 1
ป
ป
6/3
6/10
6/17
6/24
7/1
7/8
7/15
7/22
7/29
8/5
8/12
8/19
8/26
9/2
9/9
9/16
9/23
9/30
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 21 of 27
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Appendix 4: Schedule for FY02 DQ Strategy Implementation Projects (Page 2 of 2)
Week of
Distribute, and
Regional/State review of
1st Comparative Analysis
& "HPVs in AFS" DQ
Alert
Responses due from
"HP VDQ Alert"
Responses due from 1st
Comparative Analyses
Undertake 2ntl FY02
Comparative Analysis
Distribute, and
Regional/State review of
2nd FY02 Comparative
Analysis
Distribute, and
Regional/State review of
"Closing out violations in
RCRAInfo" DQ Alert
Responses due from
"Closing out violations in
RCRAInfo" DQ Alert
2/18
2/25
3/4
3/11
3/18
3/25
4/1
4/8
4/15
4/22
4/29
5/6
5/13
5/20
5/27
6/3
6/10
6/17
6/24
7/1
7/8
7/15
7/22
i i
1 1
7/29
8/5
8/12
8/19
8/26
1 1
9/2
9/9
9/16
9/23
9/30
i i
1 1
i i
1 1
4 = Will happen within specified week
| | = Will happen over specified weeks
= Will happen sometime during specified
time period
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 22 of 27
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Appendix 5
Schedule for Implementing FY03 DQ Strategy Projects (Page 1 of 2)
* = Will happen within specified month
| | = Will happen over specified months
= Will happen sometime during
specified time period
Month of:
Workshops to identify FYOSData
Quality Projects
Sub-workgroups meet /plan work
for FY03 projects
Put language in MOAs regarding
Regions implementing/overseeing
FY03DQ projects
Undertake and distribute for review
two Misuse of Fields &
Comparative Analyses
Comments due on Misuse of Fields
& Comparative Analyses
Distribute draft of FY03
Implementation Plan for to DQ
workgroup for review
Comments on FY03
Implementation Plan due
Incorporate comments on FY03
projects
4/02
*
5/02
6/02
i i
1 1
*
7/02
I i
1 1
+
8/02
9/02
10/02
i i
1 1
*
*
11/02
12/02
1/03
2/03
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 23 of 27
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Schedule for Implementing FY03 DQ Strategy Projects (Page 2 of 2)
Month of:
Initiate workgroups to conduct data
fields clean-up and guidance efforts
TTnHprtn Vp FVfn A nrlit
Distribute for review FY03 Audit
preliminary results
Distribute FY03 Audit final results
Undertake and distribute for review
FY03 Periodic Comparative
Analyses &DQ Alerts
Distribute FY03 Audit final results
4/02
5/02
6/02
7/02
8/02
9/02
10/02
11/02
*
i
1
i
1
12/02
i
1
+
1/03
i
1
i
1
2/03
i
1
+
* = Will happen within specified month
| = Will happen over specified months
= Will happen sometime during
specified time period
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 24 of 27
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Appendix 6
Examples of Existing Policies and Procedures for Minimizing Data Errors
Prior to Data Entry for Our Legacy Data Bases
A few examples of policies and procedures used by Regions and States to minimize data errors
during entry into legacy data systems and to ensure the accuracy of information are presented
below.
A. Region 3
PCS
Upon return from performing an inspection, the inspector/technical staff member is responsible
for completing a regional inspection form. The form was created by the PCS Coordinator to
collect inspection data and contains fields for collecting permit type information for those
facilities that do not have an NPDES permit and are categorized as unpermitted, general,
stormwater, etc., making it necessary to create a record in PCS before the inspection can be
entered. The form provides a list of all inspection types, inspectors, facility types, and their
associated codes. It's purpose is to provide quick and easy access to the information and
required fields to enter inspections into PCS. (The inspection form 3560-3 has not yet been
updated to include all of the new inspection type codes).
Once inspections have been entered into PCS, the weekly audit reports are checked to ensure
acceptance of the inspection. If an inspection was rejected, the problem is resolved and the
inspections are re-entered. A retrieval is also pulled to compare the inspections listed in PCS
against the inspections sheets that have been collected for the month. For quick checks, an on
line verification is used.
A similar process has been set up to collect enforcement action data using a created
Enforcement Action (EA) Summary Sheet for PCS which list only those enforcement actions
used by Region 3 and it's States. The sheet is comprised of enforcement actions and compliance
schedules by name and code, it provides the name of the initiator, the date completed, permit
number, action date, issued by, docket number, whether it's permitted or unpermitted, associated
NPDES number and name, space to list any EA related compliance scheduled events, reason for
the EA, and provides Close Out information. This form has been in existence for the past 15
years. It places all necessary information relating to the EA at your finger tips.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 25 of 27
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To QA enforcement action data in PCS, active enforcement actions and any associated
compliance schedules are pulled and circulated among the technical staff. The staff review and
update the EA status (e.g., amendments and close outs). This process is performed quarterly.
The Region has shared these procedures and tools with their States. The States of Maryland,
Pennsylvania and West Virginia have similar procedures in place for the QA/QC of their data.
B. Region 6
In the RCRA program, after the State and EPA staff return from their inspections, they write up
their inspection reports. All of Region 6's state and regional staff have peer review meetings in
their Agencies to discuss potential violations. Besides other inspectors/enforcement officers, the
Region also invites a lawyer to attend the meetings. Enforcement actions are written and case
conclusion data sheets are completed (for EPA only) and attached to the enforcement action
before the record is put into concurrence.
The States data (inspection/violation/enforcement) is usually reviewed by a supervisor before it is
given to data entry personnel. Each one of the five States operates differently. The States have
been informed for many years that they must have all inspection and enforcement actions in the
data system at the time that reports are pulled for their mid-year and end-of-reviews. When
discrepancies are discovered on the data reports, State personnel are called to resolve them. At
the Regional office, all data information pertaining to inspections, violations and enforcement
actions are reviewed in the Hazardous Waste Enforcement Branch by a program person who is
the liaison with the Regional RCRAInfo group, located in the Information Management Section.
State data entry clerks receive Regional and National training once a year. In addition, they call
Region 6's data personnel if they need any help. The Region pulls an Orphan/QA report for
States and EPA data once a month. This report denotes data entries that are not properly linked.
Also, the Region's data group has developed other reports that they run regularly to check the
Region's data.
C. Region 7
CAA
Region 7 does not have any established policy to ensure accuracy of data as it relates to the Air
Program. Data entry into the Air Facility Subsystem (AFS) is paper-driven meaning a form is
completed by the inspector or case review officer and given to the data entry person to enter the
data into AFS. The region performs a cursory review of the data from time to time, but there are
no policies in place to correct any data discrepancies.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 26 of 27
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Docket
When an administrative case has been filed with the Regional Hearing Clerk(RHC)/Docket
Analyst, the attorney assigned to the case, completes a Case Initiation Data Sheet (CIDS) and
hands this form to the RHC/Docket Analyst, who then enters this initial information into Docket.
Upon the conclusion of the case, the staff attorney completes the Case Conclusion Data Sheet
(CCDS) which is then given to an attorney for review. After the review process, the form is
given to the RHC/Docket Analyst for her to enter the information into Docket. The data
contained in Docket is frequently reviewed by the Deputy Regional Counsel. Also if the Docket
Manager at Headquarters notices any data discrepancies, he immediately notifies the
RHC/Docket Analyst of any mis-information who in turn corrects any data discrepancies.
Monthly conference calls and annual meetings are also held.
RCRA
RCRA Information is entered based on what the compliance officers provide. A mechanism used
to ensure data quality is RCRA fact sheets. RCRA fact sheets include lists of data elements that
the user is supposed to enter into the system, as well as explanations of how the database is
structured and how to assure proper data entry. Also, much of the input into the RCRAInfo
database is based on letters, notification/inspection forms and telephone conversation records
received. The originator of the information is contacted concerning any questions the data
analyst may have. RCRAInfo training has been provided to the states. RCRAInfo conference
calls are attended monthly along with annual RCRAInfo training.
D. Region 9
Region 9 has built a Lotus Notes system for reporting enforcement data to the DOCKET
Coordinator. By eliminating paper forms, and by programming edit checks, help prompts etc.
data quality has been significantly enhanced for the most recent two year period in comparison
to historical trends.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 27 of 27
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Enforcement and Compliance
Data Quality Strategy
March 25, 2002
-------
TABLE OF CONTENTS
I. Introduction 1
Relationship to Quality Management Plans 1
II. Vision Statement 2
IE. Common Data Quality Issues 3
IV. Data Quality Activities 4
A. Periodic Activities 4
Identifying Data Errors 6
Prioritizing Data Problems Found 6
Selecting Data Quality Projects and Involving the Regions and States 7
Sending Analyses of Problems to Regions and States for Correction 7
B. Ongoing Activities 8
Internet Error Correction 8
Promoting Accuracy of Reports, Paper Records, and Data Entry and Validation
Procedures 8
Updating Data System Guidance 9
System Updates and ICIS/Modernization 10
V. Regional and State Implementation of the Strategy 10
Coordinating with Other Key Activities 10
VT. Conclusion 11
Appendix 1: The Data Quality Strategy and the Office of Compliance
Quality Management Plan 12
Appendix 2: Process for Developing the Enforcement and Compliance Data Quality Strategy
and the FY02 Data Quality Strategy Implementation Plan 13
Appendix 3: Overview Chart of the FY02 Data Quality Strategy Implementation Plan 16
Appendix 4: Description and Schedule for Implementing FY02 Projects 17
A. Random Audits 17
B. Comparative Analyses 18
C. Fields Clarification 19
D. Data Quality Alerts 20
Schedule For FY02 DQ Strategy Implementation Projects 21
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
-------
Appendix 5: Schedule for Implementing FY03 DQ Strategy Projects 23
Appendix 6: Examples of Existing Policies and Procedures for Minimizing Data Errors
Prior to Data Entry for Our Legacy Data Bases 25
A. Region 3 25
B. Region 6 26
C. Region 7 26
D. Region 9 27
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
-------
I. Introduction
The Enforcement and Compliance Data Quality Strategy's purpose is to develop and implement
an ambitious, practical plan to assess and manage the quality of enforcement and compliance
data. This work is critical for EPA's own business needs throughout OECA and the Regions, for
programs in state and local governments, and for the public. A short but not exhaustive list of
reasons the Agency invests in maintaining the integrity of enforcement and compliance data
includes the following:
> High quality data in EPA's national databases is essential for credible measures, reports,
and analyses.
* EPA managers and members of Congress rely on this data to hold EPA programs
accountable and to inform their decision-making.
* Accurate data, in an accessible and usable form, is essential to support Agency planning
and targeting.
> The Government Performance and Results Act (GPRA) requires federal agencies to
develop program plans and performance measures, and to report on progress achieved
each year. Documenting performance requires timely, high quality data.
> Accurate and complete information in EPA's enforcement and compliance databases
ensures that states are properly credited for their enforcement and compliance monitoring
activities.
* Proof of high quality gives rise to confidence among the public, industry, and other users
of enforcement and compliance data, especially if the public is provided Internet access.
> Conclusions drawn in analyses and reports by OECA or outside groups using EPA data
have been challenged based on concerns about data quality. In recent years, Inspector
General reports have stressed the need for increased attention to data quality in Agency
efforts to monitor and measure enforcement and compliance programs.
Relationship to Quality Management Plans
Although Region's have their own Quality Management Plans (QMP) to ensure data quality, this
Enforcement and Compliance Data Quality Strategy covers areas not traditionally covered by
Regional QMPs. This fiscal year, OC is also updating its Office-level Quality Management Plan
(QMP), which is intended to clearly and fully document the policies, work processes, resources,
management structure, and other critical elements of OC's data quality program. For more
information on the relationship between this Data Quality Strategy and the OC QMP, please see
Appendix 1.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 1 of 27
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II. Vision Statement
The vision of the Data Quality Strategy (DQS) for enforcement and compliance data is to assure
that the data used to support enforcement program decisions are of high quality and accurately
reflect the activity and accomplishments of OECA programs. High quality data is defined as
accurate, complete, and timely data that are clearly presented and consistent with national data
standards. OC believes that assessments of data quality will demonstrate and result in improved
accuracy of enforcement and compliance. The Agency can confidently disseminate and use this
information to evaluate programs, target resources and to inform Congress, the public, and the
news media.
The DQS calls for all levels of OC and its partners to actively manage the quality of data in the
national data systems to the highest possible standards by:
* assessing the quality of enforcement and compliance data in its data systems on an
ongoing basis;
* identifying any missing, incorrect, or inadequate data; and
* responding to problems as they are identified thereby continually improving data that
does not meet data system, program, Office or Agency standards.
The Strategy is designed to reshape aa hoc data quality efforts and to establish routine and
systematic methods for improving and maintaining a high level of data quality. The focus of this
strategy will be to identify data quality problems by examining enforcement and compliance data
in Agency systems and raising issues to the appropriate personnel for further analysis and
correction. When data quality problems are found to be due to the inherent structure of a
database or to established data processing procedures, these issues will be raised both to the
appropriate system managers and to the Integrated Compliance Information System (ICIS)
modernization team, who can act on many of the recommended improvements in
software/hardware specifications, as well as data entry, verification, and documentation.
The following principles will guide implementation of the strategy:
> Research into problems and analyses will focus on real data and its usage.
> Critical analyses will be objective. Analytical techniques that yield comprehensive
assessments, such as random sampling of entire data systems, will be used rather than
anecdotal investigations. Where practical, root cause analyses will be undertaken to
identify systemic reasons for inadequate data quality, which will help formulate practical
solutions.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 2 of 27
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Responsibilities for finding solutions to data quality problems will be clear. Expectations
for performance will be established.
Implementation options to improve data quality will be realistic and feasible. In some
cases, FY02 data quality assessments may examine a longer time period, but
implementation options will be limited to remedying only the two most recent years of
data.
I. Common Data Quality Issues
The data quality activities discussed in this Strategy are specifically aimed at identifying data that
is missing, incorrect, or inadequate. Definitions of these terms are provided below.
Missing Data refer to required files, records or values that are not in the EPA national databases
due to incomplete reporting by EPA Headquarters, EPA Region, a state agency, a local authority,
or facility. This deficiency precludes accurate program evaluations and could suggest that
important environmental work is not being done.
Incorrect Data are values within a field that do not accurately represent the true value. There are
three main reasons for data in a required field to be incorrect. These reasons are data creation
errors, data entry errors, and ambiguity in use of data fields.
Data Creation Errors: Programmatic staff can err while filling out forms that are
forwarded to data entry staff or when entering data online. Some of these errors can be
the result of ambiguity in guidance (see below), poorly designed data reporting tools,
overlapping systems requiring a staffer to report the same data for entry into two or more
systems, and lack of management emphasis on the importance of submitting complete,
high quality data. Facilities may also generate errors in preparing required reporting (e.g.,
monthly discharge monitoring reports required by CWA permits).
Data Entry Errors: Mistakes may be made during data entry by data entry staff or, more
rarely, by translator programs. Mistakes may also be due to a lack of data quality checks
prior to data entry. For example, established procedures to verify the information on
paper records (e.g., inspection reports, enforcement action reports, Case Conclusion Data
Sheets) may be inadequate. Finally, there may not be sufficient training and tools
provided to staff who enter data to ensure data are entered properly.
Ambiguity in Use of Data Fields: Misinterpretations and/or inadequate guidance
concerning what data should be in required fields may result in inconsistency in values
across Regions and states and others.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 3 of 27
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Inadequate Data ate defined as records or fields that are not accessible or usable as currently
maintained in EPA national databases. For example, data fields might exist in systems, but EPA
does not require reporting or has allowed the fields to fall into disuse. Alternatively, new data
needs may have arisen due to programmatic changes and the data systems were not modified to
meet those needs. In other instances, inadequate data may result if regulations or policies have
not been updated to match new goals, technologies, or systems.
IV. Data Quality Activities
This Data Quality Strategy proposes various activities to identify and correct current data quality
problems. Annually, OC will develop an enforcement and compliance Data Quality Strategy
Implementation Plan in consultation with Regions and states. The goal of the plan will be to
identify specific data quality issues through periodic activities, such as audits and analyses. The
outcome of these activities will be used to prioritize the order in which to address any data
problems. Resulting analyses will be sent to Regions and states for review and correction where
appropriate. Ongoing activities, such as the development of online correction, will be
undertaken at the same time to address data quality problems that are long-term projects or may
require activities on repeating schedules (e.g., training).
Proposed activities are organized and described in this section according to whether they are
periodic or on-going. Figure 2 shows how the activities fit within the DQS and how they are
expected to complement each other.
A. Periodic Activities
OC will develop an annual Data Quality Strategy Implementation Plan in consultation with the
Regions and states. The plan will identify specific projects for the coming year. It will include
relevant details and planning information for:
> identifying data errors;
> prioritizing problems found;
* selecting data quality projects and involving Regions and states; and
> sending analyses of problems to Regions and states for correction.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 4 of 27
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Figure 2: Activities Established by the Data Quality Strategy
;
I Periodic Activities:
Random
Audits
Periodic
Comparative
Analyses
Analyses of
Discrepancies
in the Use of Fields
Expert Nominated
Problems
Process
for
Prioritizing
Problems
Found
|
>,
Analyses
of Problems
Sent to
Regions/
States
for
Correction
[Ongoing Activities*
I ^^^^^^^^H^^^^^^^^^^^^^^^^^^^H
I Internet error correction
i
! Developing, revising, and maintaining:
| training and tools for data entry clerks
| data entry and validation procedures
| policies and procedures to ensure the accuracy of the
| information on paper records
| Clarification of guidance on fields and new program guidance
I
| ICIS/Modernization efforts and changes to legacy systems
*Any of these ongoing activities may uncover problems that need to be addressed more formally. In
addition, the solutions for some of the prioritized problems may result in revisions or new data entry
procedures, clarification of guidance, or system changes/modernization.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 5 of 27
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Identifying Data Errors
Data problems will be identified through methods such as: random data audits; comparative
analyses; analyses of discrepancies in the use of fields; and expert nominated problems. Each of
these is described below.
> Random Data Audits. Data in selected key data fields will be independently evaluated
through random data audits to validate its accuracy and completeness.
> Periodic Comparative Analyses. Periodically, comparative analyses of particular data
fields across organizational units with delegated authority will be conducted to identify
potential data quality problems. For example, comparing Significant Non-Compliance or
inspection rates within Regions or states to the national average can be used to identify
extreme outlying values that might indicate data problems.
* Analyses of Discrepancies in the Use of Fields. OC will analyze key enforcement and
compliance activity data fields to determine if there are discrepancies in Regional or state
usage. Discrepancies found will be documented, and guidance developed to assist
program implementers and database users in how to use the codes for nationally
consistent reporting.
* Expert Nominated Problems. Staff with significant experience and expertise with
individual data systems (data system staff, program staff or expert users) will identify any
quality issues they encounter. It is expected that such data quality problems will be
identified from intensive usage, such as targeting and measures analyses. In addition,
data problems found by comparing data required to be entered into more than one
database can be used to reconcile information across data systems.
Prioritizing Data Problems Found
Once data problems are identified, they will be prioritized by a standing data quality workgroup
that will consult with relevant stakeholders. Data quality efforts will focus on:
data in the legacy database that will next be modernized;
administrative priorities of stakeholder agencies and offices involved in management of
each data system;
EPA administration priorities;
areas of concern raised by the Environmental Council of the States (ECOS), the Inspector
General, EPA Management, Regional information users and managers;
areas of concern discovered by methodologies for identifying data problems (see Figure
2, 'Periodic Activities');
areas of concern raised by public access; and
Regional and state review of assessments that confirm validity of the problems.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 6 of 27
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Selecting Data Quality Projects and Involving the Regions and States
Development of the annual Data Quality Strategy Implementation Plan will follow a structured
decision making process. This process will resemble the one used for development of the FY02
Implementation Plan (Appendix 2) and is described below. Each year, OECA's MOA Guidance
will specify the number of national data quality projects for EPA and states to work on during
each year.
The process will start with an annual Data Quality Strategy workshop held in the spring.
Participants will include staff from headquarters, Regions and state representatives. Workshop
participants will:
discuss issues related to the identification and implementation of the current year's
projects; and
brainstorm ideas for the next year's projects.
Sub-workgroups will be convened to build upon the discussions from the Data Quality Strategy
workshop and to flesh out the projects to be recommended for implementation as well as
methods for analyzing them. During the summer, the sub-workgroups will make their
recommendations, which will then be sent to the entire Data Quality Strategy workgroup for
review and comment.
The detailed implementation plan for the upcoming year will then be drafted and distributed to a
wider set of stakeholders. This implementation strategy will be distributed for review and
comment to the entire data steward community, including ECOS, before being finalized.
Information on planning, assignment of responsibilities, progress, and results will be coordinated
with Regions and states, via the Regions. State and Regions will have scheduled opportunities to
communicate their comments on the projects to Headquarters.
Sending Analyses of Problems to Regions and States for Correction
Once the data quality problems are identified via Periodic Comparative Analyses, Analyses of
Discrepancies in the Use of Fields, and Expert Nominated Problems and assessments are
complete, and problems are researched and well documented, Regions and states will be
informed of the problems through distribution of analysis reports in various formats (e.g., short
DQ alerts, longer memoranda). These reports will describe in detail an identified data quality
problem narratively, and, where applicable, graphically and quantitatively. They will be written
for the selected problems and sent to the responsible Regions, states (via the Regions), and
Headquarters personnel to alert them of potential data problem so they can correct the data
already in the system and make any other changes needed to avoid the problems in the future.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 7 of 27
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B. Ongoing Activities
The following activities will be undertaken on an ongoing basis to uncover, prioritize and
address data quality problems:
* Internet error correction;
> promoting accuracy of initial reporting, paper records, data entry, and validation
procedures;
> updating a variety of guidance documents for activities that affect data quality; and
* updating data system documentation and support system modernization and ICIS
development.
Many of these activities will be influenced by and will influence the periodic activities described
in the previous section (see Figure 2). For example, data errors identified through periodic
audits and analyses may spur changes to ongoing data quality work (e.g., revisions to data entry
procedures, clarification of guidance, or system changes/modernization). In turn, the ongoing
data quality activities will directly impact the types and number of data quality concerns.
Internet Error Correction
Currently available Internet error correction tools will be applied to particular records in need of
correction. For example, OC will use information from the Headquarters, Regional, and state
data steward networks, as well as the (Online Tracking Information System) OTIS site (and the
Public Access Internet site when it becomes available) and its error correction process to pin-
point data records within OC's national databases in need of correction. The Office of
Environmental Information (OEI) is expected to improve the online system for informing data
stewards at the Regional and state level about potential problems with individual records
reported by data system users. OKI's system will also track the performance of Regional and
state data stewards responsible for making corrections. Resources and encouragement from
program management will be critical to ensure the continued and effective involvement of those
data stewards responsible for responding to error correction requests.
Promoting Accuracy of Reports, Paper Records, and Data Entry and Validation Procedures
Regions and states are expected to commit resources to enter required data into EPA's national
databases in a timely and accurate manner. The following are examples of activities OC may
undertake, or encourage the Regions and states to undertake, to ensure that data quality
procedures are accurately documented and followed.
> Utilize and document existing edit and validation checks in the legacy databases, and
make recommendations for new edit and validation checks to be incorporated into ICIS as
the databases are modernized. As part of OC's Quality Management Plan (discussed in
the Appendix 1), Data System Quality Assurance Plans will be developed for the each of
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 8 of 27
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the data systems for which OC has primary responsibility. The Data System Quality
Assurance Plans will describe the existing and planned editing checks and validation
procedures that are part of each data systems.
* Develop new policies and procedures to minimize data errors stemming from the filling
in of field reports and paper records (e.g., inspection reports, enforcement action reports,
case conclusion data sheets). Distribute these procedures to the staff responsible for entry.
This may include procedures for tracking documents and standardizing document storage.
Some examples of existing database policies and procedures for minimizing data errors
prior to data entry are listed in Appendix 6.
> Provide training for all staff generating and entering data that ultimately resides in EPA's
data systems. Policies and procedures may need to be reviewed for delegated programs
directly entering data into EPA's national databases as well as for states using translator
programs.
> Where the training of data entry personnel is adequate, review the rejected transactions
for a specific period of time. In some cases, the data problems may be due to a "process"
rather than data entry errors. For instance, duplicate discharge monitoring reports
(DMRs) for the NPDES program may be continuously routed for data entry, causing
numerous "record on file" rejects.
> Inform Regional and national program management of the need for sufficient resources to
support the implementation of more comprehensive and accurate data entry and
verification procedures. Please refer to Appendix 6 for examples of existing policies and
procedures for minimizing data errors. For example, disinvestment in accurate, complete
data entry and correction for NPDES minors in the Permit Compliance System has eroded
the quality of enforcement and compliance data for this universe of over 87,800 facilities.
> Conduct a one-time review of instructions for data submission to ensure that Regions and
states provide data in formats consistent with data system requirements (e.g., values
and/or formats should be consistent with data system or translatable with full
documentation).
Updating Data System Guidance
Data system guidance and documentation will be updated to address discrepancies in the use of
key enforcement and compliance activity database fields. Fields that are inconsistently used by
Regions and states could stem from different understandings of how database fields are to be
used, or from outdated media-specific program guidance.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 9 of 27
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System Updates and ICIS/Modernization
OC will work to maintain current, well documented system data dictionaries for those systems
run by OC. Such efforts to create and maintain all required documentation will be explicitly
called for as part of OC's Quality Management Plan. These data dictionaries should provide
clear definitions of data fields and, when necessary, clear definitions of programmatic terms,
such as, what a "final judicial order" means for the RCRA program.
OC will also work with the modernization team to ensure that the data quality improvements
recommended by the Data Quality Strategy are built into the modernized data systems.
V. Regional and State Implementation of the Strategy
Since Regions and states are responsible for entry of enforcement and compliance information,
their active participation in data quality efforts is critical. OECA's Memorandum of Agreement
Guidance will continue to specify the Region's level of commitment to implementing the DQS.
OC will propose the following efforts to ensure Regions and states implement the activities of
this Data Quality Strategy:
* Provide yearly quality assurance awards to states.
> Do not give credit for program actions and results that are not entered in a national
database. Notify programs, Regions and state staff and management of this policy.
> Make any OECA discretionary extramural funding given to states dependent on whether
the state commits to and prioritizes maintaining quality data. Maintaining quality data
includes providing the data in a form consistent with EPA data system requirements and
codes.
Coordinating with Other Key Activities
The proposed data quality planning, implementation, and assessments will be coordinated with
other activities to further encourage state and Regional participation in data quality efforts.
These activities are listed below.
> Highlight data quality issues in the Regional profiles that are provided to senior
management.
* Expand program status review reports to include additional data quality information.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 10 of 27
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Publish data quality statistics for Regions to promote positive peer pressure.
Communicate findings related to database design issues that affect data quality to the
ICIS team.
Raise data quality issues through the Enforcement and Compliance Performance Board.
Provide annual expectations for data quality goals and/or participation in data quality
activities in MO As.
Emphasize data quality in National Environmental Performance Partnerships (NEPPS)
and grant guidances.
VI. Conclusion
In FY2001, the Office of Compliance began developing this Data Quality Strategy (DQS) for
assessing and actively managing the quality of enforcement and compliance information. The
DQS sets forth the National Enforcement and Compliance Program's vision for assuring that the
data used to support enforcement program decisions are sound and accurately reflect the
activities and accomplishments of the program. The DQS also calls for a variety of data quality
assessments of EPA data systems which will be undertaken in FY2002 and subsequent years.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 11 of 27
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Appendix 1
The Data Quality Strategy and the Office of Compliance Quality Management Plan
The updated OC Office-level Quality Management Plan (QMP) will detail how components of
the DQS, such as data quality assessments, will inform ongoing planning and implementation of
data quality activities and data system management. Figure 1 shows an outline of the major
sections in OC's Quality Management Plan and how portions of the Strategy will fit within it.
Figure 1: How the Data Quality Strategy Fits Within OC's Quality Management Plan
Quality Management Plan
Management and Organization of OC
(Include DQS Introduction, Vision Statement, Description of
OC's Data Quality Workgroup)
Quality System Components
(Include DQS Activities and Data Quality Strategy
Implementation Plan)
Personnel Qualifications and Training
Procurement of Items and Services
Documents and Records
Computer Hardware and Software
Planning
Implementation of Work Processes
Assessment and Response
(Include DQS Random Audit of Inspection Data, Comparative
Analyses, Analyses of Discrepancies in the Use of Compliance
and Enforcement Data Fields, Data Quality Alerts)
Quality Improvement
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 12 of 27
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Appendix 2
Process for Developing the Enforcement and Compliance Data Quality Strategy and the
FY02 Data Quality Strategy Implementation Plan
On May 21, 2001 a call memorandum was sent from Michael Stahl asking for workgroup
members to develop a Data Quality Strategy for Enforcement and Compliance Data.
Representatives from the media program offices and staff who work directly with EPA
maintained enforcement and compliance national databases (DOCKET, AFS, PCS, RCRAInfo,
FTTS, and SDWIS) signed up for the workgroup as well as Headquarter personnel (particularly
those involved with measures, targeting, and data system management).
On June 20, 2001, a Data Quality Strategy workshop was held in Washington. This served as
the first workgroup meeting. There were presentations at the workshop on:
* an overview document providing a vision statement, definitions, and an initial outline of
the Data Quality Strategy,
> methodologies for identifying, validating, and correcting of data problems and Errors;
* data errors on the front end; and
* documentation, guidance, and modernization - their impact on data quality.
In addition, we had brainstorming sessions in the afternoon. Discussions included:
> various options for conducting the identification and correction of errors;
* coming up with a list of problems we know about in terms of data entry;
* coming up with a list of policies and procedures for entering data; and
> coming of with lists of database fields needing clarification.
On June 28, 2001 summaries of the three breakout sessions were sent to the entire Data Quality
Strategy workgroup. On July 6, 2001, the next version of the vision statement, definitions, and
outline of the Data Quality Strategy was sent to the workgroup for comment along with
documents which grouped the information from the three June 20 workshop breakout sessions
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 13 of 27
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into categories and tasks. We asked workgroup members to get back to us with comments on
these documents and the tasks they preferred to work on.
From these responses two sub-workgroups were created:
1) Tasks on Methodologies for Identification of Data Problems and Correcting Errors
(led by David Sprague)
2) Tasks on Potential Fields Needing Clarification: Know Areas where Potential Misuse
or Inconsistent Use is Occurring (led by Lynn Vendinello)
We also sent a list of overall, cross-cutting tasks for which we requested input from as many as
people as possible.
We did not initiate a sub-workgroup on Data Quality on the Front End. We asked the data
system managers to provide us with write-ups describing what data entry and validation checks
are already programmed into our national databases. On June 18, 2001, we requested the Data
Quality Strategy workgroup members provide us with information on policies and procedures
their Regions and states have to ensure the accuracy of the information on the paper records
(e.g., inspection reports, enforcement action reports, case conclusion data sheets) before they are
transmitted to data entry staff. We also requested information on what training and tools are
provided to staff who enter data to ensure the data will be entered accurately.
The number of data quality projects which are being recommended for FY02 were decided upon
by the data quality and targeting teams of the Information Utilization & Targeting Branch
(IUTB), and OC management consensus. The sub-workgroups and the data quality and targeting
teams of IUTB recommended projects. Appendix 3 provides an overview of the data quality
projects planned for implementation in FY02. Appendix 4 describes the projects in more detail
and presents a schedule for implementation. Appendix 5 presents a schedule for FY03 projects.
The Potential Fields Needing Clarification sub-workgroup helped decide which fields will be
analyzed and how the analyses will be done. The Identification of Data Problems and Correcting
Errors sub-workgroup helped develop the Random Audit of Inspection Data project as well as
the Comparative Analyses charts. The decisions made by these sub-workgroups were made with
consultation from the data quality and targeting teams of the Information Utilization & Targeting
Branch (IUTB). In addition, the targeting team of IUTB nominated two data quality alerts to be
sent to the user communities early in 2002.
The next step in the review process was to send the recommended data quality projects and
analyses to the entire Data Quality Strategy workgroup for review and comment. For example,
the entire Data Quality Strategy workgroup were sent:
1) the proposals for how to analyze the four codes needing clarification,
2) the proposed methodology for conducting the random audit of inspection data,
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 14 of 27
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3) sample periodic comparative analyses charts,
4) two data quality alerts proposed by the targeting team of IUTB.
Since the Data Quality Strategy workgroup is composed of headquarters and Regional database
and program representatives, as well as one state representative, their input was essential.
Once the comments by the Data Quality Strategy workgroup were received, the FY02 Data
Quality Implementation Plan was completed. This plan provides detailed outlines of all the data
quality projects which will be conducted in 2002. Before finalizing the plan, the Implementation
Plan was sent to all the affected user communities, including ECOS, for their review and input.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 15 of 27
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Appendix 3
Overview Chart of the FY02 Data Quality Strategy Implementation Plan
DQ Activity
Random Audits
Comparative Analyses
Fields Clarifications
Data Quality Alerts
Level of Activity
One per year
Analyses of 4
indicators, three media
projects issued semi-
annually
New fields are to be
analyzed each year
2 issued annually
Current Proposed
Project
Inspection Fields of
AFS, PCS, and
RCRAInfo
Inspection Coverage,
formal enforcement
actions, penalties and
SNC data in AFS, PCS,
and RCRAInfo
PCS Enforcement
Action Codes
4 RCRA fields
One Air: One RCRA
Correction/
Identification
Method Proposed
Select permits/facility
ID's randomly. Post
inspection data from
national data systems
for those ID's on
website.
State level values
compared against
national averages
Investigate current
usage of data fields and
bring findings back to
workgroup
Discoveries currently
being brought to
workgroup attention.
Regional Involvement
Compare paper records
to posted data on
website. States/Regions
can indicate
discrepancies online.
Follow-up with states
that show low outlier
values (e.g., less than
half the national ave.).
Workgroup established
to develop responses for
each field needing
clarification.
Clean up data as
indicated
State Involvement
Compare paper records
to posted data on WEB
site. Indicate
corrections
States with low outlier
values will have to
certify validity of data
or explain problem.
Workgroup established
to develop responses for
each field needing
clarification.
Clean up data as
indicated
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 16 of 27
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Appendix 4
Description and Schedule for Implementing FY02 Projects
The following Appendix describes the projects that OC plans to implement during FY02. An
implementation schedule for FY02 projects is presented at the end of this appendix. For further
information on any of these projects, please contact David Sprague (sprague.david@epa.gov).
A. Random Audits
Objective: To quantify the accuracy and completeness of selected fields as maintained in
the federal data systems.
Example of the type of statements that will be supported by the audit results. 1 he inspection
information maintained by Hฑf\ is &u /O accurate. LJased on the survey methodology used, we
QฃO/ QO/ "
are &u /O confident that this error rate is within O/O of the true value.
* This year's audit will examine inspection data only.
* The audit will focus separately on populations within each of the three media databases:
/ Facilities subject to CAA programs as defined by the RECAP universe = 42,075
ป/" Facilities with active, major water permits = 6,670
/ Facilities defined as TSDs and LQGs in RCRAInfo = 23,046
* An audit of 8 facilities per program and state is designed to minimize respondent burden
for the Regions and states and will yield statistically valid results with which to
characterize accuracy of inspection information in the national data systems.
> Reviewing this number of facilities should provide a large enough sample size to have
95% confidence in the results, with an error rate of+/- 3%.
Random Audits: Comments and Responses
The following comments were made by states and Regional staff on earlier drafts of the audit
methodology:
* Comment: The universe of facilities sampled should include more facilities from larger
states and less from smaller states.
Response: In developing the random audit, OC was sensitive to not overburdening
individual states. The sample size of eight is based on the number of permit IDs
necessary from the largest states (in terms of federally reportable inspections) to obtain
results that allow EPA to be 95 % confident that the results are within a reasonably small
confidence interval. The sample size of eight does lead to over sampling from smaller
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 17 of 27
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states. This over sampling of some states should provide a cushion by helping to address
the possibility that some states will not fully participate. Statistical weighting of the audit
results will adjust for over sampling in some smaller states.
* Comment: States should be able to check the hard copy data against their state/local data
system at the same time they check the data on the proposed Data Quality Website.
Response: Others in the workgroup believe that it is not always the same person who
would check the hard copy and the state/local data systems. To reduce confusion and
workload, OC feels that it is appropriate to keep the focus of the random audit on
checking discrepancies in the federal data systems. A follow-up request to check
state/local data system will be made only if discrepancies are found.
> Comment: States will need notification regarding this effort during the once a year
EPA/state MOA or PPG negotiations.
Response: This is a relatively small effort and is directly related to compliance with the
Data Quality Strategy. As such, it should be considered as included in the previously
negotiated MO As. In developing the random audit, EPA was sensitive to not
overburdening individual states. In any given state program, checking eight records is not
expected to be a significant burden.
B. Comparative Analyses
Objective: To identify potential data quality problems (outliers) by comparing state-level
statistics to an established benchmark (i.e., 1A national average).
The following activities are proposed for FY02:
* Comparative analyses charts for RCRA, CWA, and CAA which show all the states sorted
by percentages and will include:
/ Inspection coverage
/ Ratio of formal enforcement actions to number of facilities inspected
/ Ratio of HPV/SNC facilities per facilities in violation
> The Regions overseeing states that fall below a performance threshold (i.e., one-half the
national average) would be sent a memorandum asking them to
/ discuss the findings of the comparative analyses;
S certify data is accurate; and
S determine cause for missing data.
* Comparative Analyses: Comments and Responses
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 18 of 27
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Comments by members of the Workgroup included:
* Comment: For air, comparative charts of enforcement actions/total # facilities and
HPVs/total # facilities make more sense than having # of inspections and # violations as
the denominators.
Response: Using the number of inspections in the denominator is an appropriate
measure of data quality, rather than using the number of facilities. This approach to the
data quality assessment of actions takes into account two factors that are expected to be
related to the reported number of actions: 1) the number of facilities and 2) the number of
inspections (the amount of effort put forth by the program). The same logic applies to
the SNC analysis. That is, disregarding the level of effort put forth by the program will
change the results and highlight states that do not have many facilities in violation.
> Comment: It would be good to coordinate these analyses with the annual audits Regions
conduct of states regarding specific facilities.
Response: The Regions are encouraged, as much as possible, to coordinate the concerns
raised by these analyses with their audits of their States.
C. Fields Clarification
Objective: Identify discrepancies in the use of key enforcement and compliance data fields.
* RCRA Fields Clarification: The workgroup of Regional and Headquarters members have
participated in a series of conference calls to identify the appropriate use and definition
of informal vs formal action codes, and the applicability of corrective action codes as
they pertain to the enforcement program. The group has received input from the RCRA
and Corrective Action enforcement program offices indicating the appropriate use of
existing codes to address enforcement and/or corrective action remediation. A guidance
package is being developed and will include specific scenarios to assist program
implementers in determining how to use the codes for nationally consistent reporting.
Completion of the draft guidance package is expected by mid-March, 2002.
* Four RCRAInfo codes were examined:
i/" RCRA New Violation or Roll-Over of Existing Violations,
/ Appropriate Entry of Formal and Informal Actions,
/ RCRA 500 vs. 600 Series,
S Corrective Action Codes in the Enforcement Module.
* In addition, a DQ sub-workgroup identified one PCS code for study:
/ Compliance Schedule Event Codes
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 19 of 27
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Fields Clarification: Schedule
* Donna Inman is working on the necessary guidance and clean-up related to the 4 RCRA
codes studied.
* The PCS Enforcement Action Clean-up guidance will be distributed in final soon.
* A workgroup has not begun yet to work on clean-up of the compliance event schedule
codes in PCS.
D. Data Quality Alerts
Objective: Address data quality problems identified by data users (e.g. targeting,
measures, and Regional analysis)
* Two Data Quality alerts have been chosen:
i/" HPV facilities being entered into AFS without any underlying violations being
entered into the system.
S Regions and States failing to close out violations in RCRAinfo
* Two more data quality alerts will be written and distributed later in the year
Data Quality Alerts: Comments and Responses
> Comment: Some reviewers misunderstand the concept of a Data Quality Alert.
Response: Language will be added to the Data Quality Alerts describing their purpose
and what responses are expected from the Regions and States.
> Comment: Manual updating of the HPV flag is no longer necessary. The excerpt from
Appendix A of the T&A HPV Workbook does not reflect this.
Response: Clarifying language will be added to the CAA data quality alert to respond to
these concerns.
* Comment: Facilities could have come into compliance more than 2 years ago but still
have HPV status since not all penalties have been paid yet. This effort may prove to be a
lot of work with little return if the data is found to be valid for many facilities.
Response: Clarifying language will be added to the CAA data quality alert to respond to
these concerns.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 20 of 27
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Appendix 4: Schedule for FY02 DQ Strategy Implementation Projects (Page 1 of 2)
* = Will happen within specified week
| | = Will happen over specified weeks
= Will happen sometime during
specified time period
Week of
Data review prior to
public access announced
Data review for public
access site
Release of public access
site
FY02 Audit instructions
sent out
State and Regional audit
of sampled inspection
records
Distribute, and
Regional/State review of
FY02 Audit preliminary
results
Comments on FY02 Audit
prelim results due
Distribute FY02 Audit
final results
Clean-up of RCRA fields
2/18
2/25
3/4
3/11
3/18
ป
3/25
4/1
4/8
4/15
4/22
4/29
5/6
5/13
5/20
5/27
1 1
1 1
ป
I i
1 1
1 1
1 1
ป
ป
6/3
6/10
6/17
6/24
7/1
7/8
7/15
7/22
7/29
8/5
8/12
8/19
8/26
9/2
9/9
9/16
9/23
9/30
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 21 of 27
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Appendix 4: Schedule for FY02 DQ Strategy Implementation Projects (Page 2 of 2)
Week of
Distribute, and
Regional/State review of
1st Comparative Analysis
& "HPVs in AFS" DQ
Alert
Responses due from
"HP VDQ Alert"
Responses due from 1st
Comparative Analyses
Undertake 2ntl FY02
Comparative Analysis
Distribute, and
Regional/State review of
2nd FY02 Comparative
Analysis
Distribute, and
Regional/State review of
"Closing out violations in
RCRAInfo" DQ Alert
Responses due from
"Closing out violations in
RCRAInfo" DQ Alert
2/18
2/25
3/4
3/11
3/18
3/25
4/1
4/8
4/15
4/22
4/29
5/6
5/13
5/20
5/27
6/3
6/10
6/17
6/24
7/1
7/8
7/15
7/22
i i
1 1
7/29
8/5
8/12
8/19
8/26
1 1
9/2
9/9
9/16
9/23
9/30
i i
1 1
i i
1 1
4 = Will happen within specified week
| | = Will happen over specified weeks
= Will happen sometime during specified
time period
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 22 of 27
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Appendix 5
Schedule for Implementing FY03 DQ Strategy Projects (Page 1 of 2)
* = Will happen within specified month
| | = Will happen over specified months
= Will happen sometime during
specified time period
Month of:
Workshops to identify FYOSData
Quality Projects
Sub-workgroups meet /plan work
for FY03 projects
Put language in MOAs regarding
Regions implementing/overseeing
FY03DQ projects
Undertake and distribute for review
two Misuse of Fields &
Comparative Analyses
Comments due on Misuse of Fields
& Comparative Analyses
Distribute draft of FY03
Implementation Plan for to DQ
workgroup for review
Comments on FY03
Implementation Plan due
Incorporate comments on FY03
projects
4/02
*
5/02
6/02
i i
1 1
*
7/02
I i
1 1
+
8/02
9/02
10/02
i i
1 1
*
*
11/02
12/02
1/03
2/03
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 23 of 27
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Schedule for Implementing FY03 DQ Strategy Projects (Page 2 of 2)
Month of:
Initiate workgroups to conduct data
fields clean-up and guidance efforts
TTnHprtn Vp FVfn A nrlit
Distribute for review FY03 Audit
preliminary results
Distribute FY03 Audit final results
Undertake and distribute for review
FY03 Periodic Comparative
Analyses &DQ Alerts
Distribute FY03 Audit final results
4/02
5/02
6/02
7/02
8/02
9/02
10/02
11/02
*
i
1
i
1
12/02
i
1
+
1/03
i
1
i
1
2/03
i
1
+
* = Will happen within specified month
| = Will happen over specified months
= Will happen sometime during
specified time period
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002
Page 24 of 27
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Appendix 6
Examples of Existing Policies and Procedures for Minimizing Data Errors
Prior to Data Entry for Our Legacy Data Bases
A few examples of policies and procedures used by Regions and States to minimize data errors
during entry into legacy data systems and to ensure the accuracy of information are presented
below.
A. Region 3
PCS
Upon return from performing an inspection, the inspector/technical staff member is responsible
for completing a regional inspection form. The form was created by the PCS Coordinator to
collect inspection data and contains fields for collecting permit type information for those
facilities that do not have an NPDES permit and are categorized as unpermitted, general,
stormwater, etc., making it necessary to create a record in PCS before the inspection can be
entered. The form provides a list of all inspection types, inspectors, facility types, and their
associated codes. It's purpose is to provide quick and easy access to the information and
required fields to enter inspections into PCS. (The inspection form 3560-3 has not yet been
updated to include all of the new inspection type codes).
Once inspections have been entered into PCS, the weekly audit reports are checked to ensure
acceptance of the inspection. If an inspection was rejected, the problem is resolved and the
inspections are re-entered. A retrieval is also pulled to compare the inspections listed in PCS
against the inspections sheets that have been collected for the month. For quick checks, an on
line verification is used.
A similar process has been set up to collect enforcement action data using a created
Enforcement Action (EA) Summary Sheet for PCS which list only those enforcement actions
used by Region 3 and it's States. The sheet is comprised of enforcement actions and compliance
schedules by name and code, it provides the name of the initiator, the date completed, permit
number, action date, issued by, docket number, whether it's permitted or unpermitted, associated
NPDES number and name, space to list any EA related compliance scheduled events, reason for
the EA, and provides Close Out information. This form has been in existence for the past 15
years. It places all necessary information relating to the EA at your finger tips.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 25 of 27
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To QA enforcement action data in PCS, active enforcement actions and any associated
compliance schedules are pulled and circulated among the technical staff. The staff review and
update the EA status (e.g., amendments and close outs). This process is performed quarterly.
The Region has shared these procedures and tools with their States. The States of Maryland,
Pennsylvania and West Virginia have similar procedures in place for the QA/QC of their data.
B. Region 6
In the RCRA program, after the State and EPA staff return from their inspections, they write up
their inspection reports. All of Region 6's state and regional staff have peer review meetings in
their Agencies to discuss potential violations. Besides other inspectors/enforcement officers, the
Region also invites a lawyer to attend the meetings. Enforcement actions are written and case
conclusion data sheets are completed (for EPA only) and attached to the enforcement action
before the record is put into concurrence.
The States data (inspection/violation/enforcement) is usually reviewed by a supervisor before it is
given to data entry personnel. Each one of the five States operates differently. The States have
been informed for many years that they must have all inspection and enforcement actions in the
data system at the time that reports are pulled for their mid-year and end-of-reviews. When
discrepancies are discovered on the data reports, State personnel are called to resolve them. At
the Regional office, all data information pertaining to inspections, violations and enforcement
actions are reviewed in the Hazardous Waste Enforcement Branch by a program person who is
the liaison with the Regional RCRAInfo group, located in the Information Management Section.
State data entry clerks receive Regional and National training once a year. In addition, they call
Region 6's data personnel if they need any help. The Region pulls an Orphan/QA report for
States and EPA data once a month. This report denotes data entries that are not properly linked.
Also, the Region's data group has developed other reports that they run regularly to check the
Region's data.
C. Region 7
CAA
Region 7 does not have any established policy to ensure accuracy of data as it relates to the Air
Program. Data entry into the Air Facility Subsystem (AFS) is paper-driven meaning a form is
completed by the inspector or case review officer and given to the data entry person to enter the
data into AFS. The region performs a cursory review of the data from time to time, but there are
no policies in place to correct any data discrepancies.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 26 of 27
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Docket
When an administrative case has been filed with the Regional Hearing Clerk(RHC)/Docket
Analyst, the attorney assigned to the case, completes a Case Initiation Data Sheet (CIDS) and
hands this form to the RHC/Docket Analyst, who then enters this initial information into Docket.
Upon the conclusion of the case, the staff attorney completes the Case Conclusion Data Sheet
(CCDS) which is then given to an attorney for review. After the review process, the form is
given to the RHC/Docket Analyst for her to enter the information into Docket. The data
contained in Docket is frequently reviewed by the Deputy Regional Counsel. Also if the Docket
Manager at Headquarters notices any data discrepancies, he immediately notifies the
RHC/Docket Analyst of any mis-information who in turn corrects any data discrepancies.
Monthly conference calls and annual meetings are also held.
RCRA
RCRA Information is entered based on what the compliance officers provide. A mechanism used
to ensure data quality is RCRA fact sheets. RCRA fact sheets include lists of data elements that
the user is supposed to enter into the system, as well as explanations of how the database is
structured and how to assure proper data entry. Also, much of the input into the RCRAInfo
database is based on letters, notification/inspection forms and telephone conversation records
received. The originator of the information is contacted concerning any questions the data
analyst may have. RCRAInfo training has been provided to the states. RCRAInfo conference
calls are attended monthly along with annual RCRAInfo training.
D. Region 9
Region 9 has built a Lotus Notes system for reporting enforcement data to the DOCKET
Coordinator. By eliminating paper forms, and by programming edit checks, help prompts etc.
data quality has been significantly enhanced for the most recent two year period in comparison
to historical trends.
Final Enforcement and Compliance Data Quality Strategy (DQS) March 25, 2002 Page 27 of 27
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MEMORANDUM
SUBJECT: Enhancing EPA's Compliance Assistance Programs
FROM: Sylvia K. Lowrance
Acting Assistant Administrator
TO: Regional Administrators, Regions I-X
The purpose of this memorandum is to recommend a number of actions to enhance EPA's
compliance assistance programs and encourage compliance assurance strategies which give due
consideration to the full range of compliance and enforcement tools. To achieve Goal 9 of EPA's
Strategic Plan ("provide a credible deterrent to pollution and greater compliance with the law"),
EPA will need to use all its tools - assistance, incentives, monitoring and enforcement - in an
integrated fashion to promote compliance with environmental requirements. As you may recall
from the FY2003 Operating Year Priorities Meeting in January, the Office of Enforcement and
Compliance Assurance (OECA) has identified better integration of compliance assistance into our
enforcement strategies as one of five priorities for the national program.
In order to identify ways of better integrating our compliance assurance efforts, managers
from the Office of Compliance's(OC) Compliance Assistance and Sector Programs Division
visited all ten regions to discuss the national and Regional compliance assistance programs.
Based on these visits and other analyses, we have identified steps we all can undertake to
strengthen the foundation of the compliance assistance program. We discussed the results and
recommendations of these visits at our Senior Enforcement Managers Meeting in San Francisco in
January. During that meeting, we discussed four basic actions Regions can take to improve
regional compliance assistance programs. We also agreed to form a senior level steering
committee to deal with compliance assistance policy and implementation issues at the national
level. This memorandum outlines the recommendations for the Regions and the charge for the
National Steering Committee on Compliance Assistance Policy and Infrastructure (CAPI).
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BUILDING AN EFFECTIVE COMPLIANCE ASSISTANCE PROGRAM
The Regional visits identified several characteristics which seemed to enhance Regional
compliance assistance programs. Each of these are described below:
1. Management Support. The strongest Regional assistance programs provide support
for compliance assistance at all management levels - senior, mid-level and front-line
Management needs to provide perspective about using the appropriate mix of tools to address
noncompliance and highlight the value of integrated strategies in increasing both the efficient use
of resources and program effectiveness.
2. Organizing Mechanism. A second important characteristic of effective compliance
assistance programs is establishment of a formal network, workgroup or other mechanism to
foster communication and coordination among internal regional compliance assistance
practitioners as well as with external environmental assistance providers. For example, some
regions have created a formal compliance assistance workgroup of compliance and program
personnel. The establishment of a central coordinator for compliance assistance can be a
tremendous asset in establishing and maintaining these mechanisms. Other Regions have chosen
to create an organizational structure that facilitates communication and coordination among the
compliance assistance, enforcement, monitoring, program and pollution prevention personnel.
3. Other Characteristics. Regional programs which possess the building blocks of a
strong compliance assistance program may also exhibit a variety of the following secondary
characteristics which strengthen their programs:
* Undertake initiatives using a problem-solving approach which considers all
appropriate compliance assurance tools. Region II used this approach in its universities
initiative to identify the environmental problems that needed to be addressed and develop a
strategy that utilized compliance assistance, incentives, monitoring and enforcement;
> Practice strategic coordination and planning between the Region and states on
national and Regional compliance assistance priorities and activities. Region VI, for
example, meets with its states on compliance assistance priorities as part of the state grant
and MOA negotiations;
> Employ proactive efforts to target environmental problems that could be addressed, at
least in part, by compliance assistance.
* Support inspectors who make compliance assistance part of their routine activities;
> Use measures of success to highlight results and efficiencies of combined or integrated
efforts to address significant problems. Region III managers recently launched two
compliance assistance outcome measurement projects over the course of two summers to
assess behavioral, process and environmental changes at facilities.
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TAKING ACTION TO STRENGTHEN THE PROGRAM
The characteristics discussed above are based on the best practices from our analysis of
Regional compliance assistance programs. Each Region should begin efforts to ensure the
following components are in place to strengthen the compliance assistance program in particular
and the compliance assurance program overall.
1. Establish a Regional Compliance Assistance Coordinator
Creating this position recognizes that compliance assistance is a vital and dynamic part of
EPA's mission and will provide a focal point for information on, and organization of, ongoing
compliance assistance activities. A more detailed description of the Coordinator's role is outlined
in Attachment 1.
Coordinators should be senior people who can articulate the Region's vision and
commitment to compliance assistance and be knowledgeable about the Region's efforts. In
addition, Coordinators should be able to interact effectively with Regional enforcement and
compliance monitoring personnel, and the Office of Compliance's Regional Analysts.
Coordinators should have access to regional senior managers on compliance assistance issues.
Ideally, they will work with or for the Regional Enforcement Coordinator or the Enforcement
Division Director, and perform in a manner similar to MO A, pollution prevention and federal
facilities coordinators.
The Coordinator position should utilize the expertise already developed by Regional
compliance assistance staff, particularly members of the Agency-wide workgroup that helped
develop the National Compliance Assistance Clearinghouse, the Compliance Assistance Activity
Plan, and the Compliance Assistance Forum. We foresee that the Coordinator's responsibilities
will entail 0.5 to 1 FTE per Region. Seven additional FTE have been redirected to the compliance
assistance program component in FY 2002 for distribution among the ten regional offices which
can help cover resources for the Coordinator position.
2. Establish a Formal Compliance Assistance Communication Network
Establish a mechanism to facilitate ongoing communication, coordination and planning
among compliance assistance and other environmental assistance providers both within the
Regional office and with states and other external parties. Some Regions have created formal
workgroups, teams, and /or e-mail group lists to make Regional assistance efforts more visible,
strategic and effective.
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3. Coordinate with States on Compliance Assistance Planning
In preparation for the next MOA cycle, each Region should coordinate with its states in
planning for compliance assistance activities to support national and regional priorities as well as
core activities. Preplanning with the states on compliance assistance is, in fact, an element of the
Core Compliance Assistance Program (Attachment 2). Few Regions actually discuss compliance
assistance strategically and as part of the overall compliance assurance program in planning how
to fulfill MOA commitments.
4. Strategically Build Compliance Assistance into the National and Regional Planning Processes
Beginning in FY 2003, use the Compliance Assistance Projects Reporting Form to help
strategically integrate compliance assistance into your overall compliance and enforcement
program. This form was piloted in FY2001 by five Regions and was effective in ensuring
management engagement and coordinated up-front planning during the MO A process. Based on
discussions with these Regions and analysis of Headquarters information needs, we have revised
the form for use by all Regions. Further, ensure that staff are familiar with the revised Core
Compliance Assistance Program (Attachment 2) that is part of the FY 02-03 MOA guidance.
The guidance sets out the current compliance assistance activities that should be a part of your
compliance assurance program.
ESTABLISHING THE COMPLIANCE ASSISTANCE POLICY AND
INFRASTRUCTURE (CAPI) STEERING COMMITTEE
At the Senior Enforcement Managers Meeting in San Francisco in January, 2002 several
issues surrounding the basic infrastructure and policies of the national compliance assistance
program were raised. There was general agreement that a senior level steering committee was
needed to improve the policies and infrastructure of the compliance assistance program to ensure
that it is more fully integrated with the national compliance assurance program. This steering
committee will make recommendations to the senior managers that build on the four basic actions
identified above and will also include the following issues :
1. Reviewing the core compliance assistance framework for both the national and regional
programs and suggesting changes to ensure a strong compliance assistance infrastructure;
1. Identifying ways to integrate compliance assistance more prominently in the MOA
process;
2. Creating and using common measures for results of compliance assistance activities and
highlighting compliance assistance achievements in the Annual Performance Report and
other venues;
3. Developing a strategy to pilot integrated strategies in FY 2003 across the Regions that
includes measurable results for compliance assistance.
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The Office of Compliance will be establishing this Steering Committee over the next
month, and will be requesting the participation of several Regional and Headquarters managers.
Once the group is established, we will outline the membership and the specific charge on an
upcoming Senior Managers conference call in early March. Our expectation is that this group will
formulate recommendations on these issues for us to discuss at the next Senior Managers meeting
this summer.
Thank you for helping to improve the overall compliance and enforcement program by
strengthening your compliance assistance programs. Please send the name of your Compliance
Assistance Coordinator to Deborah Thomas, Chief of the Compliance Assistance Policy and
Integration Branch by March 14, 2002, at mail code 2224, by fax at (202) 564-7083, or by E-
mail at Thomas.Deborah@epa.gov. Please feel free to contact Michael Stahl, Director of the
Office of Compliance, if you have any questions concerning this memorandum.
Attachments
cc: Deputy Regional Administrators
Michael Stahl, Office of Compliance
Lisa Lund, Office of Compliance
Eric Schaeffer, Office of Regulatory Enforcement
Connie Musgrove, Office of Regulatory Enforcement
Division Directors, Office of Compliance and Office of Regulatory Enforcement
Regional Enforcement Division Directors and Coordinators
EPA Compliance Assistance Workgroup
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ATTACHMENT 1
THE ROLE OF THE COMPLIANCE ASSISTANCE COORDINATOR
Regional Expert: Serve as the "expert" within the region on regional compliance
assistance priorities, strategies, and performance measurement.
Regional Coordination: Serve as the focal point for coordinating regional response to
requests from Headquarters and regional participation in national compliance assistance
initiatives and the compliance assistance components of integrated compliance assurance
strategies.
Coordinate with Lead Region and the Office of Compliance: Coordinate with the
Lead Region for compliance assistance, OC's Regional Analysis and Coordination Team,
and OC's Compliance Assistance and Sector Programs Division on compliance assistance
issues or activities that are or should be integrated with enforcement initiatives, involve
potential resource tradeoffs, or need a coordinated response from OECA.
Planning and Integration: Work with the Regional Enforcement and MOA
Coordinators in developing and implementing national and regional compliance assistance
priorities and strategies during the MOA process and other planning processes.
Involve states in compliance assistance planning and priority setting. Ensure that regional
activities related to MOA priorities are integrated into the annual Compliance Assistance
Plan.
Compliance Assistance Plan and Clearinghouse Input: Coordinate regional input into
the National Compliance Assistance Clearinghouse and the Compliance Assistance
Activity Plan.
Tool Wholesaling and Promotion: Promote compliance assistance in regions, states,
and tribes and provide compliance assistance tools and materials to compliance assistance
providers and inspectors.
Policy Development: Assist in the development of OC's compliance assistance policies
and guidance.
Information Sharing: Share lessons learned about compliance assistance activities and
tools with other regions to maximize effectiveness of the compliance assistance program
through monthly conference calls, periodic national meetings, and other vehicles.
Coordination with States, Tribes, and Other Providers: Coordinate and share tools,
information and best practices with state and tribal compliance assistance providers, Small
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Business Assistance Providers, Small Business Development Committees, and other
compliance assistance providers.
Tracking and Accountability: Coordinate compliance assistance tracking and
measurement activities within the Region, including coordinating regional input into the
Regional Compliance Assistance Tracking System.
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ATTACHMENT 2
FY 2002/2003 MOA Compliance Assistance Core Program
All Regional programs should:
Utilize compliance assistance, as appropriate, to help ensure that the regulated community
understands its regulatory obligations and how to comply with environmental
requirements and track and measure the results of compliance assistance activities.
Compliance Assistance includes activities, tools or technical assistance which provide clear
and consistent information for 1) helping the regulated community understand and meet its
obligations under environmental regulations; or 2) compliance assistance providers to aid the
regulated community in complying with environmental regulations. At least one objective of
compliance assistance must be related to achieving or advancing regulatory compliance.
Compliance assistance may also help the regulated community find cost-effective ways to comply
with regulations and/or go "beyond compliance" through the use of pollution prevention,
environmental management practices and innovative technologies, thus improving environmental
performance. The core national compliance assistance program in the Regions consists of the
following activities:
> Conducting workshops/training, making presentations at meetings, developing
compliance assistance tools, distributing outreach material, conducting on-site
visits, providing telephone/hotline assistance
* Focusing compliance assistance efforts on targeted environmental problems, as
well as on new rules, SBREFA rules or economically significant rules targeting, in
particular, small businesses and communities which often lack expertise to
understand technical environmental regulations.
> Using compliance assistance in integrated enforcement strategies, as appropriate
* Contributing Regional projects to the annual Compliance Assistance Activity Plan
> Measuring the outputs of compliance assistance activities and outcomes of selected
activities
> Reporting on compliance assistance activities in the Reporting Compliance
Assistance Tracking System (RCATS)
> Serving predominantly as a "wholesaler" of compliance assistance to enable other
assistance providers to offer assistance directly to the regulated community.
"Retail" or direct assistance should be focused on non-delegated programs and
national/Regional initiatives, as appropriate.
* Promoting national compliance assistance tools and activities
such as the National Compliance Assistance Clearinghouse, the Compliance
Assistance Centers and Compliance Assistance Forum
> Using compliance assistance materials in conjunction with the Small Business
Compliance Policy and encouraging states to adopt EPA's 1995 Small
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Communities Policy
> Coordinating with Headquarters, other EPA Regions and other compliance
assistance providers, such as states, on compliance assistance needs and activities
and enabling providers to leverage resources
> Holding an annual Regional stakeholder meeting(s) to obtain feedback on
compliance assistance planning
> Assisting in compliance assistance targeting and data analysis, e.g., in selecting
sectors that need assistance and developing compliance assistance materials
Regions should undertake these compliance assistance activities strategically, employing
integrated planning and use of compliance assistance tools, as appropriate, tracking the results
and measuring the effectiveness of compliance assistance activities. Inspectors providing Tier I or
Tier II compliance assistance during compliance inspections in accordance with the
recommendations of the Role of the EPA Inspector in Providing Compliance Assistance should
refer to the Core Compliance Monitoring Program Activities section.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
ENFORCEMENT AND
COMPLIANCE ASSURANCE
March 19, 2003
MEMORANDUM
SUBJECT: Measuring Compliance Assistance Outcomes
FROM: Michael M Stahl /s/
Director
Office of Compliance
TO: Regional Enforcement Division Directors
OC Division Directors
Regional Enforcement Coordinators
The purpose of this memorandum is to advance measurement of compliance assistance
outcomes in the national enforcement and compliance assurance program. As you know, the
proposed Goal 5 of the revised Agency Strategic Plan under the Government Performance and
Results Act (GPRA) includes a variety of outcome measures for compliance assistance (see
Attachment 1). Outcomes such as pollution reductions, improvements in facility environmental
management practices, and increased understanding of environmental requirements will need to be
measured for our compliance assistance activities when the new Strategic Plan goes into effect.
In addition to accountability for meeting GPRA targets, the Assistant Administrator for
Enforcement and Compliance Assurance is routinely using outcome data to examine the
performance of the compliance assurance program. Over the last few years, we have made
considerable progress in measuring the outputs and outcomes of compliance assistance activities.
We are just now beginning to receive compliance assistance outcome information from the
regions and need to build on this momentum
Action Plan for Measuring Compliance Assistance Outcomes
Clearly, it is challenging to measure the outcomes of our assistance activities. We are
working to build capacity, develop measurement "tools" and "templates" and standardize
compliance assistance outcome reporting to help us achieve this goal. Our strategy will only be
successful if compliance assistance measurement is routinely incorporated into the planning and
implementation of our activities. We need to continue to track our compliance assistance activity
outputs and strategically undertake outcome measurement.
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In Fiscal Year 2003-2004, we need to collect and report data that will support our Goal 5
compliance assistance performance measures. As mentioned above, the three outcome measures
are:
* increased understanding of environmental requirements;
* improved environmental management practices; and
> reduced pollution.
To enable us to meet this challenge, I'm asking that you undertake three actions that will help us
increase the number of projects with outcome measurement components as well as generate better
data to support our GPRA commitments. Beginning in 2003:
* compliance assistance activities that support the National OECA priorities or
Regional priorities should measure outcomes using a follow-up method or activity
(e.g., survey, post test, on-site revisit) (Attachment 2);
* compliance assistance workshops/training should include apre-test/post-test to
measure changes in understanding; and
> contract and grant activities involving compliance assistance (e.g. the integrated
strategies funded through headquarters, the State compliance assistance projects
funded through STAG grants) should include outcome measures as well.
Contractors/grantees are accountable for providing these results to the Office of
Compliance. Include the attached output/outcome measurement requirements
language in all Requests for Proposals (RFPs) (Attachment 3). Contractor/grantee
performance should be evaluated, in part, using agreed- upon measurement
activities.
Office of Compliance Support for Regional GPRA Outcome Measurement Activities
To support your measurement activities, the Office of Compliance will:
1. Provide measurement training for all ten Regions and Headquarters in 2003. The training
supplements the newly revised Guide for Measuring Compliance Assistance Outcomes
("the yellow book"), provides hands-on exercises for every section and addresses the
proposed Goal 5 measures.
1. Continue to work with the Compliance Assistance Policy and Infrastructure (CAPI)
Steering Committee to develop guidance on consistent measures, definitions and strategies
to:
a) implement the Goal 5 Compliance Assistance performance measures; b) develop
compliance assistance program data standards; and c) develop other program measures to
tell a clear and compelling story of the effectiveness of the compliance assistance program.
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-3-
2. Provide support and guidance to contractors/grantees who must fulfill compliance
assistance outcome measurement requirements.
3. Incorporate both RCATS and CAPD1 into the Integrated Compliance Information System
(ICIS) for FY 2004 to facilitate compliance assistance reporting for Goal 5 and beyond.
4. Continue to conduct monthly measurement calls (third Thursday in the month, 1:00 - 2:00
EST, 202-260-8330 1142#), to provide project support for compliance assistance
measurement.
5. Support two measurement specific Web sites on the OECA Web page:
http://www.epa.gov/compliance/planning/results and the National Environmental
Compliance Assistance Clearinghouse
http://cfpub.epa.gov/clearinghouse/index.cfm?TopicID=C: 10:650. The sites have a
collection of measurement resources in one place and we will continue to develop and
post additional templates, surveys and other tools on these two sites as they come
available.
Both Rochele Kadish in the Compliance Assistance and Sector Programs Division
(CASPD) (564-3106) and Lynn Vendinello in the Enforcement Planning Targeting and Data
Division (EPTDD) (564-7066) are available to help support your measurement efforts. Generally,
Rochele will help you develop the measurement tool, discuss implementation, and analyze data
whereas Lynn will help with your Information Collection Requests and getting the final data into
RCATS/ICIS.
I look forward to seeing progress in our ability to report on and learn from measuring
compliance assistance outcomes. If you have any questions please feel free to call me or contact
Rochele or Lynn.
Attachments
cc: J.P. Suarez
Phyllis Harris
Deputy Regional Administrators
Lisa Lund
OC Deputy/Associate Division Directors
OC Branch Chiefs
Regional Compliance Assistance Coordinators
Rochele Kadish
Lynn Vendinello
'Reporting Compliance Assistance Tracking System & Compliance Assistance Planning Database
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Attachment 1
GOAL 5 COMPLIANCE. PREVENTION. AND STEWARDSHIP
Improve environmental performance through compliance with
environmental requirements preventing pollution, and promoting environmental
stewardship. EPA and its partners will promote stewardship through incentives
for governments, businesses, and the public to better protect human health and
the environment.
OBJECTIVE 1: Maximize compliance to protect human health and the environment
by achieving a X% increase in the pounds of pollution reduced
through compliance assistance, compliance incentives, and
enforcement by FY 2008; and achieving a X% increase by 2008, in
the number of regulated entities making improvements in
environmental management practices.
Subobjective 1.1: Prevent noncompliance and reduce environmental risks by
achieving: a X% increase by 2008, in the percentage of
regulated entities that improved their understanding of
environmental requirements as a result of EPA assistance; a
X% increase by 2008, in the number of regulated entities
that improved environmental management practices as a
result of EPA assistance; a X% by 2008, in the percentage
of regulated entities that reduced pollution as a result of
EPA compliance assistance.
Compliance Assistance [194.2 FTE and 5.1 M]
(Note: The principal measures listed with each sub-objective focus on
outcomes. The other measures provide additional important information
for understanding performance in meeting the subobjective. The numeric
targets and the time periods are pending requiring further refinement and
additional discussion with program management and staff.)
Principal Measures:
Percentage of regulated entities receiving direct compliance
assistance (e.g., training, on-site visits, etc) from EPA
reporting that they increased their understanding of
environmental requirements as a result of EPA assistance.
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Percentage of regulated entities receiving direct compliance
assistance (e.g, training, on-site visits, etc.) from EPA
reporting that they improved environmental management
practices as a result of EPA assistance.
Percentage of regulated entities receiving direct assistance
(e.g., training, on-site visits, etc.) from EPA reporting that they
reduced pollution as a result of EPA assistance.
Percentage of regulated entities seeking assistance from EPA-
sponsored compliance assistance centers reporting that they
increased their understanding of environmental requirements as a
result of their use of the centers or the clearinghouse.
Percentage of regulated entities seeking assistance from EPA-
sponsored compliance assistance centers reporting that they
improved environmental management practices as a result of their
use of the centers or the clearinghouse.
Percentage of regulated entities seeking assistance from EPA-
sponsored compliance assistance centers reporting that they
reduced pollution as a result of their use of the centers or the
clearinghouse.
Other Measures:
Number of regulated entities seeking compliance assistance from
EPA-sponsored centers or the EPA compliance assistance
clearinghouse.
Number of regulated entities reached through direct EPA or EPA-
sponsored/funded compliance assistance.
Percentage of non-EPA assistance providers reporting
improved ability to deliver compliance assistance as a result
of using EPA compliance assistance tools and resources.
Percentage of EPA or EPA- sponsored/funded compliance
assistance projects undertaken as part of an integrated
strategy or approach.
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Attachment 2
The table below shows the appropriate follow-up method for different compliance
assistance activities and the outcome measures that can be gathered as a result.
Through the use of checklists, pre-test / post tests and survey questions, we will be
able to gather the data necessary to assess the outcomes of our activities. Some
examples of questions that would help us to assess the outcomes of our activities
include:
Increased Understanding
Did your understanding of environmental regulations improve as a result
the ?
Improved environmental management practices
What regulatory actions do you intend to take (did take) as a result of the
?
What process changes at your facility do you intend to make (did make)
as a result of the ?
What management changes at your facility do you intend to take (did
take) as a result of the ?
Who (if anyone) have you contacted (will contact) for further assistance
as a result of the ?
Reduced pollution - only for mail/phone surveys or on-site revisits
Did you reduce pollution as a result of the Compliance Assistance
information you received?
Compliance Assistance
Activity
Follow-up Methods
Outcome Measure
Onsite Visits
On-site revisits
Phone/Mail/email
survey
Reduction in Pollution
Environmental Management
Improvements
Increased Understanding
Workshops /
Training
On-site Pre/posttest
Environmental Management
Improvements
Increased Understanding
Phone/Mail/email
survey
Reduced Pollution
Environmental Management
Improvements
Increased Understanding
Tools (e.g., manuals)
Phone/Mail/email
survey
Reduced Pollution
Environmental Management
Improvements
Increased Understanding
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Compliance Assistance
Activity
Web Sites
Follow-up Methods
Online survey
Outcome Measure
Environmental Management
Improvements
Increased Understanding
Attachment 3
Measurement Language for Requests For Proposals:
Measurement Requirements:
1. Collect and make information available relating to the implementation of your project,
your performance against your objectives and targets, and changes in compliance that
occur as a result of the project.
Outputs (required)
Activities undertaken
Number of entities reached
Outcomes (one outcome measure is required)
Increased understanding
Improved environmental management practices
changes in regulatory behavior (e.g., getting a permit)
changes in non-regulatory behavior (e.g. implementing best management
practices, process changes, self-audits)
changes in compliance
Reduced pollution
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DRAFT 5/1/08
Revised 4/29/11
Regional Plan for Region 8's Implementation of the State Review Framework
(SRF), Uniform Enforcement Oversight System (UEOS) and Other Oversight
Activities for the CWA NPDES, CAA Stationary Sources, RCRA Subtitle C,
and Public Water System Supervision (PWSS) Enforcement Programs
through FY 2012
Overview
The nature and scope of oversight activities and documentation of program assessments and
reviews for state RCRA Subtitle C, NPDES, CAA Stationary Source, and Public Water System
Supervision (PWSS) enforcement programs is dependent upon performance as documented
during the previous year and, therefore, may vary from year to year. This differential oversight
will range from minimum or baseline oversight for strong programs to SRF or UEOS program
assessments every other year for those programs with ongoing significant problems. Each year,
the results of activities and assessments/reviews that have occurred during the year will be
documented by ECEJ in an end-of-year (EOY) report, State Review Framework (SRF) report, or,
for the Public Water System Supervision (PWSS) enforcement program, a Uniform Enforcement
Oversight System (UEOS) report. States will have an opportunity to review and comment on
EOY reports and SRF/UEOS reports. Planned oversight activities for each year will be
documented in a State Oversight Plan and provided to states. The following table provides some
examples of how the level and frequency of various oversight activities are impacted by program
performance.
Examples of Differential Oversight as a Function of Program Performance
Oversight Activity
Good Performance
Poor Performance
Periodic Comprehensive Review
Frequency of SRF/UEOS
review.
Once every four
years
More frequent than
every four years.
Annual/Ongoing Oversight
Number of files reviewed
during EOY review.
Areas for improvement tracked
(as detailed, primarily, in SRF
Tracker).
Data Metrics review.
Frequency of routine, periodic
program communications.
10 or less.
Few or none.
Limited review.
Quarterly to semi-
annually.
15 or less.
More.
Targeted, more in
depth review.
Monthly to quarterly.
Program Assessment Using the OECA/ECOS SRF and UEOS
At least once every four years, state RCRA Subtitle C, NPDES, and CAA Stationary Source
enforcement program performance will be evaluated using the OECA/ECOS SRF and associated
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guidance. Likewise, PWSS enforcement program performance will continue to be evaluated
using the UEOS and the frequency of reviews will be once every two to four years.
Program performance as determined by the most recent SRF or UEOS review will impact the
frequency of program assessments using SRF or UEOS. The use of performance in determining
review frequency is described in more detail below. Other factors impacting the schedule for
SRF reviews for Round 2 (through FY 2012) include the need to spread the workload out over
the four year cycle, the size of the state programs, and travel considerations. The schedule for
the SRF reviews for Round 2 is attached. Each state's next PWSS enforcement program review
using UEOS is planned for FY 2012.
The SRF is based on Region 8's UEOS and was developed jointly by the EPA Office of
Enforcement and Compliance Assurance (OECA), all ten EPA Regions, the Environmental
Council of States (ECOS) Compliance Committee and state representatives from each of the ten
EPA regions. The SRF was developed as a tool to assess state enforcement and compliance
assurance program performance and to provide a mechanism for EPA regions, working
collaboratively with their states, to ensure that states meet agreed upon performance levels.
Additional information regarding the SRF can be found at: http://www.epa-
otis.gov/otis/stateframework.html
Like the Round 1 SRF reviews, the Round 2 reviews will include reviews of all three programs
in a state at the same time. This will minimize the burden on the states, the Region, and OECA
by maximizing the efficiency of the review process (e.g. cross-program kick-off and close out
meetings, cross-program process communications, report review, etc.) and will result in a more
timely cross-program summary of findings.
Annual Program Review
Oversight activities occurring during years in which SRF or UEOS reviews are not planned will
range from a minimum or baseline level of oversight to a more enhanced level of oversight
(including targeted oversight activities) as described in the table below. Should annual oversight
activities demonstrate that program performance has either significantly improved or declined
since the last annual review, then the planned oversight for the next year will be adjusted
accordingly.
For PWSS, Region 8 also conducts annual on-site (audit) visits with each state to review the
effectiveness of the state enforcement programs, as resources allow. These visits are conducted
between November and February, and some of the information gathered is used for the UEOS
evaluation. Region 8 staff review the files of specific public water systems and evaluate
whether the state addressed each priority system in a timely manner and whether the state
followed its enforcement escalation policy. In addition, Region 8 staff review the files of
specific public water systems and evaluate how the state has responded to violations and the
accuracy of data contained in state and federal databases. A report documenting the findings of
the visit is issued to the state. As a part of the review, Region 8 identifies corrective actions that
the state should implement to improve its enforcement program, and such actions may be
incorporated into the PPA along with UEOS findings.
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Program Performance and Differential Oversight
Performance Status
Program standards are met (may have
small problems in some areas) for all
programs.
Program standards are generally met,
however, some areas for
improvement have been identified for
some programs.
For any program, program standards
are generally not met, or, there are
significant deficiencies in key areas.
Resultant Oversight
SRF every four years (UEOS for PWSS program).
Minimum / baseline oversight activities during "off
years.
SRF potentially more frequent than every four years
(UEOS for PWSS program). Baseline plus targeted
oversight activities during "off years.
SRF potentially more frequent than every four years.
Baseline plus targeted oversight activities during "off
years. Additional escalating actions if progress is not
made to correct problem areas.
Baseline oversight activities to occur every year will include:
Review and documentation (through ECEJ End of Year Report) of progress towards
meeting grant commitments,
Routine communications and information sharing with state (to discuss, for example,
HPVs, SNC, QNCR, etc.). For example, the frequency of periodic conference calls with
the state may range from quarterly to semi-annually.
Watch List review and follow-up,
Limited Data Metrics review (focusing on significant changes in performance and on
areas of concern from previous reviews),
Limited after-the-fact review of state enforcement, inspection, and related files. These
reviews may occur either on-site (in the state's offices) or off-site (at EPA's offices). The
number of facility files to be reviewed for each program will be no more than ten. The
process used for the selection of files to be reviewed will be consistent with the SRF file
selection protocol (i.e. random and representative).
Follow-up on open action items/recommendations from previous reviews (including
those identified in the SRF Tracker).
Other oversight activities required by national program guidance (e.g. oversight
inspections, etc.).
Targeted oversight activities may also include (in addition to baseline activities):
Targeted program improvement plans to be incorporated into PPAs.
More frequent communications and information sharing with state. For example, the
frequency range for periodic conference calls with the state may be increased to
monthly.
Increased number of oversight inspections.
If data problems identified, targeted, more in depth data metrics review.
Additional, targeted, after-the-fact and real time review of state files. The number of
facility files to be reviewed after-the-fact for each program may increase to no more than
15. These files will include files targeted for review to focus on problem areas identified
in addition to the random and representative files selected. Additionally, a number of
targeted, real-time file reviews may also be conducted.
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Documentation of Oversight Activities
End of Year Reports will be completed annually for all programs. For those years in which SRF
reports (or UEOS for PWSS) are completed, they will serve the purpose of the EOY report. EOY
reviews and documentation through the EOY Reports may utilize applicable portions of the SRF
or UEOS guidance (e.g. review metrics), as appropriate. At a minimum, End of Year reports
will incorporate the results of the minimum/baseline activities described above and the scope
will address the following review areas: 1) inspections, 2) enforcement activity, 3) annual
agreements, and 4) data management.
Specific oversight activities planned and actions planned to address any areas for improvement
will be described in the final SRF or UEOS report, the State Oversight Plan, and incorporated by
reference into the next PPA, as appropriate.
Review Schedule
While oversight and program review and assessment activities occur throughout the year, formal
documentation of results doesn't begin until after data are available for the year under review
and state EOY reports have been received. This is generally the middle of February following
the year under review.
Draft documentation of annual program assessments/review will be completed by the end of
April of the year after fiscal year reviewed. This is to allow findings and any corrective actions
to be incorporated into the PPA negotiation process for the following fiscal year. The SRF
guidance includes a comprehensive process for developing the report which includes many
opportunities for findings to be discussed with states and for states to review and comment on
draft reports prior to finalization. Final SRF reports will be completed by the end of the fiscal
year following the fiscal year reviewed.
EOY reports documenting oversight activities and review results (for years in which an
SRF/UEOS assessment is not conducted) will be finalized by the end of April following the
fiscal year under review. Below is a summary of the state planning and oversight cycles and the
schedule for the Round 2 SRF reviews.
4
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Summary Region 8 State Planning and Oversight Cycles for Enforcement
May 1
Final UEOS report (if applicable) provided to state.
If no SRF (or UEOS for PWSS), final EPA End of Year report provided to
state.
PPA Guidance for next fiscal year provided to states.
Draft Oversight Plans for next fiscal year provided to states.
July
May - August
Sept 30
Dec 31
February
Draft SRF report (if applicable) provided to state for review.
State Director's Meeting and State Visits (kick-off planning for next FY
including plans for oversight).
SRF report (if applicable) is finalized and provided to state.
Final Oversight Plans for next fiscal year provided to states.
PPAs in place.
State End of Year Reports received from states.
Data for prior fiscal year available in OTIS and SRF Data Metric Reports.
Schedule for Round 2 SRF Reviews
This schedule is based on several considerations including program performance as determined
by the FY 07 SRF review, the need to spread the workload out over the four year cycle, the size
of the state programs, and travel considerations. Significant changes in program performance
observed throughout cycle may result in change to review schedule. Specifically, program
performance was considered as follows:
States with one or more programs that don't meet standards or in which significant
deficiencies are identified are reviewed first.
States in which all three programs reviewed have areas of improvement/Tracker
items identified are generally reviewed prior to states in which one or more
programs do not have areas of improvement/Tracker items identified.
States with more total areas of improvement/Tracker items identified are generally
reviewed prior to states with fewer areas of improvement/Tracker items.
Other considerations include the need to spread the workload out over the four year
cycle, the size of the state programs, and travel considerations.
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Schedule for SRF Round 2
FY 2007
Round 1 comprehensive SRF review completed in all six states and in all 3 programs (18
programs overall)
FY 2008
No comprehensive SRF reviews. Scope of annual oversight (i.e. baseline/targeted) for all
states/programs is dependent upon performance as determined during the Round 1 SRF
review completed in FY 2007 and was described in the final SRF reports.
FY 2009
State A
State B
Round 2 comprehensive SRF Review for all 3 programs
Round 2 comprehensive SRF Review for all 3 programs
Scope of annual oversight (i.e. baseline/targeted) for other states/programs will be
dependent upon performance determined in previous FY and described in the State
Oversight Plan for each state.
FY 2010
State C
State D
Round 2 comprehensive SRF Review for all 3 programs
Round 2 comprehensive SRF Review for all 3 programs
Scope of annual oversight (i.e. baseline/targeted) for other states/programs will be
dependent upon performance determined in previous FY and described in the State
Oversight Plan for each state.
FY2011
State E | Round 2 comprehensive SRF Review for all 3 programs
Scope of annual oversight (i.e. baseline/targeted) for other states/programs will be
dependent upon performance determined in previous FY and described in the State
Oversight Plan for each state.
FY 2012
State F | Round 2 comprehensive SRF Review for all 3 programs
Scope of annual oversight (i.e. baseline/targeted) for other states/programs will be
dependent upon performance determined in previous FY and described in the State
Oversight Plan for each state.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C 20460
OCT31 1985
Of
WATIH
MEMORANDUM
SUBJECT: Permit Compliance System (PCS) Policy Statement
FROM: Lawrence J. Jensen ccฃ
Assistant Administrator for Water (WH-556)
TO: Regional Water Management Division Directors
Regions I - X
I am pleased to issue the attached policy statement on the
Permit Compliance System (PCS). This policy statement represents
an important step in the continuing effort to, support a reliable
and effective automated information system for the National Pollutant
Discharge Elimination System (NPDES) program.
PCS is the national data base for the NPDES program. It
serves as the primary source of NPDES information for EPA, NPDES
States, Congress, and the public. The use and sunport of PCS by
EPA Regions and NPDES States are crucial to the effectiveness and
proper"oversight of the NPDES program. This policy statement
establishes for SPA and NPDES States the key management practices
and resoonsibilities central to PCS' ability to contribute to the
overa1 1 integrity of the NPDES program and the achievement of our
lona-term environmental goals. One of the requirements is to have
Reaions and States enter all required data into PCS by Septemner 30,
19ง6 (see Attachment 1 of the PCS Policy Statement). While the aim
of the policy is a consistent approach across Regional and State
NPDES programs, it retains flexibility for Regions and States to
tailor" agreements to the unique conditions of each State.
The PCS Policy Statement is effective immediately. The Office
of Water Enforcement and Permits will monitor implementation of the
policy statement and issue special instructions as necessary.
Reaional Water Management Division Directors and their State coun-
teroarts are resoonsible for ensuring that their staffs receive suf-
ficient support to apply the principles of the policy to their PCS
activities.
I look forward to a strong commitment to this policv statement
bv rPA and State NPDES orograms. You can be assured of my full
support as EPA and the States move forward with its implementation.
Attachments
cc: Administrator
Deputy Administrator
State Directors
PCS Steerina Committee
PCS Users Grcus
-------
PERMIT- COMPLIANCE SYSTEM POLICY STATEMENT
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
STATEMENT OF POLICY
It is EPA policy that the Permit Compliance System (PCS) shall
be the national data base for the National Pollutant Discharge
Elimination System (NPDES) program. All EPA Regions must use PCS
directly, and all NPDES States must either use PCS directly or
develop and maintain an interface.
As our primary data source, PCS will promote national consis-
tency and uniformity in permit and compliance evaluation. To
acVeve national consistency and uniformity in the NPDES program,
thVreguired data in PCS must be complete and accurate. Facility,
oer-its (i.e., events and limits), measurement, inspection, com-
oliance schedule, and enforcement action data are required. These
?ecuired data elements are further defined in Attachments 1 and 2.
Thev comprise the Water Enforcement National Data Base (WENDB)
which has been redefined as the core of information necessary to
enable PCS to function as a useful operational and management tool
and so that PCS can be used to conduct oversight of the effective-
ness of the NPDES program.
All reouired data for NPDES and non-NPDES States must be ซ
ente'-d into PCS by September,30, 1986 and maintained regularly
the--after. This will" require Regions and States to start entering
data'as early as possible, and not wait until late FY 1986.
Bv the end of FY 1986, direct users of PCS shall establish,
wit" Office of Water Enforcement and Permits (OWEP) assistance,
a Quality Assurance program for data in PCS. The program shall
define:
monthly measurement of the level of data entered:
0 appropriate time frames to ensure that data are entered
in PCS in a timely manner; and
nationally consistent standards of known data quality
based on proven statistical methods of quality assurance.
PCS Quality Assurance shall address the completeness (for
assurance of full data entry) and accuracy of the data
entered into PCS.
AdoDtion of PCS by States should be formalized in each
Stag's $106 Program Plan, State/EPA Agreement, or in a separate
aar-ement. Each plan should clearly define EPA's and the NPDES
I!!:?! risoonsibiUties regarding PCS. The Key Management
Frances in this Policy Statement should be incorporated into
the $106 Program Plan.
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- 2 -
BACKGROUND
When the PCS Steering Committee met in March 1985, EPA
Regio^rrepresentatives Stressed the essential need for a positive
statement frn EPA Headquarters management to Regional and State
management specifically requiring the support and use of PCS.
Uck of such support nay result in an incomplete and unreliable
data base. With sufficient EPA Headquarters, Regional, and State
support, however, PCS will come to serve several major purposes
for the NPDES program:
PCS will provide the overall inventory for the NPDES program.
ซ PCS will provide data for responding to Congress and the
public on the overall status of the NPDES program. As
such, it will serve as a valuable tool for evaluating the
effectiveness of the program and the need for any major
policy changes.
PCS will encourage a proper EPA/State oversight role by iden-
tifying all major permittee violators.
* PCS will offer all levels of government an operational and
management tool for tracking permit issuance, compliance,
and enforcement actions.
-his PCS Policv Statement is a result of the Steering Committee
meet;-a It is a clear message to Regional and State management
hh-r'srs is the primary source of NPDES information, and as
such/it is to be supported wholeheartedly by all users of PCS.
-he PCS Steering Committee meeting also resulted in a
redefinition of WENDB and ratification thereof. WENDB is the
nini-Im standard of data entry which will allow PCS to function
as a~ฃซful operational and management tool (see Attachments 1
and -M EPA Reaions agreed that all WENDB elements will be
entered into PCS by September 30, 1986, and maintained regularly
thereafter.
once the reouirsd data are entered into and regularly main-
^,^-H in prs PCS will assist permits and compliance personnel
in manv Sf theif operatonal and management responsibilities.
Ss will areat'v ?educe reporting burdens for such activities
Is t- Stfltealc Planning and Management System (SPMS), and it
will"-ซduc! ef'crts needed for effective compliance tracking at
botn Reg?ona! aSd Stat. levels. Also, substantial automation of
the Quarterly Noncomnliance Report (QNCR) will save time anc
resources.
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. 3 -
IMPLEMENTATION STRATEGY
Kev Management Practices
To effectively implement and uphold this PCS Policy Statement
and enhance PCS' capabilities, there are certain key management
practices that must be implemented:
" The following milestones have been established to facilitate
the entry of all reguired data by the end of PY 1986:
- All required National Municipal Policy (NMP) data must be
entered into PCS by October 31, 1985 (See Attachment 1).
- All reguired data for non-NPDES States must be entered
into PCS by March 31, 1986.
NPDES permits shall be enforceable and tracked for compli-
ance using PCS. The Office of Water Enforcement and
Permits (OWEP) recognizes there may be situations where
permit limits and monitoring conditions are not initially
compatible with PCS data entry and tracking. In these
cases, Regions should ensure that appropriate steps are
taken by the permit writer to identify difficult permits
to the PCS coder, and to mutually resolve any coding
issues. The Regions should work closely with their NPDES
States using PCS, to address similar data entry problems
with State-issued NPDES permits.
8 WENDB is the minimum standard of data entry for PCS (see
the attached lists of data retirements). If States and
Regions wish to enter MPDES data beyond what has been required,
they raav do so. For example, if States want to enter
Discharge Monitoring Report (DMR) data for minor facilities,
the option is available in PCS and the States' may use it
as their resources allow. EPA will ensure that sufficient
computer space is available for the currently projected
use of PCS.
All DMRs submitted to EPA Regional Offices (including DMRs
submitted by NPDES States for EPA entry into PCS) must be
preprinted using the Office of Management and Budget (OMB)
approved DMR form. NPDES States directly using PCS are
not required to use the OMB-approved form; however, its
use is strongly encouraged. With the continuing demand
for more complete information and with stable, if not
diminishing,"data entry resources, it is to EPA's and
NPDES States' benefit to preprint DMRs. The use of are-
printed DMRs will greatly reduce PCS' data entry burden,
making available resources to be used in other areas
(e.g., PCS quality assurance, data entry for other PCS
records, etc.!.
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-4-
The frequency with which DMR3 are submitted to the EPA or
NPDES State is important for ensuring timely entry of
data into PCS and timely review of permittee's compliance
status. Quarterly, semi-annual, or annual submission of
DMRs creates a major data entry burden and impedes the
compliance evaluation process. As a result, the useful-
ness of DMR data for compliance evaluation decreases
substantially. Monthly submittal of DMRs alleviates this
problem and enhances PCS' effectiveness significantly. It
is recommended that monthly submittal of DMRs be incorpo-
rated into major permits as they are reissued. With approx-
imately 20 percent of the permits reissued each year, it
will take five years to complete the transition to monthly
submittal for all major permittees.
EPA Regions should coordinate with their respective States
to develop strategies that describe each State's plans to
either use PCS directly or develop an interface. These
strategies should include the rationale for selecting one
of these methods of data entry into PCS, an outline of all
requirements necessary for implementing the selected
method, the mechanisms to be used to supply sufficient
resources, and a schedule for attainment not to exceed
September 30, 1986. If a State is a current user of PCS
via one of these methods, the strategy should describe its
needs for enhancing its PCS usage or improving its PCS
interface, the mechanisms to be used to supply sufficient
resources, and a schedule for attainment not to exceed
September 30, 1936.
9 When writing or revising a Memorandum of Agreement (MOA),
the Region and State should specify the State's intent to
use or interface with PCS. The MOA should address the
rationale for selecting one of these selected methods of
data entry into PCS, an outline of all requirements neces-
sary for implementing the selected method, the mechanisms
to be used to supply sufficient resources, and a schedule
for attainment.
Responsibilities.
Office of Water Enforcement and Permits; It is OWEP's full
resoonsioility to maintain the structure (i.e., the computer
software) of PCS and to operate the system. OWEP will continue
to sunoort time-sharing funds needs, training, and the necessary
resources to continue the operation of PCS. OWEP will work with
the E?^ Regions and SPDES States to continually evaluate and
imorcve, where feasible, the system's software, time-share funding,
ฉDeration, and maintenance. OWEP will maintain a Steering Commit-
tee and User Group, organize the national meetings, and wor*
closely with the Regional and State representatives on major
decisions related to PCS.
OWEP will oversee the Regions' and States' progress in _
fulfilling this policy statement by assessing the quantity or
data entered each quarter.
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- 5 -
EPA Reaions andNPDESStates: It is the EPA Regions' and
NPDSS States' full responsibiiiLy to maintain the infrastructure
of ?CS by accurately entering data in a timely manner. Also, EPA
Regions ana NPoTs States are responsible for participating in PCS
Workgroups and contributing to improvements to PCS.
Three National PCS meetings are held each year, one for the
sซss s
Safe
necessary.
consistent and objective compliance tracking is a
.
of the regulations , EPA requests from the States all required
Information (as indicated in the attachments) for entry into PCS.
This can be achieved one of two ways:
A State Automated Data Processing (ADP) interface can be
developed" It is the EPA Region's responsibility to work
with SI NPDES State to develop an effective State ADP
interface The State, however, should take the lead in
the interface and work closely with the- Region
the interface is effective. It should be realized
svstem interfaces are often troublesome and unwieldy;
tey are^ten ineffective and limit the States' flexibility
to chanae their systems quickly to meet management needs.
In the event a State ADP interface is developed there
mSst be forLt agreement that the State will operate the
interface, maintain the interface software, anc^be fully
responsible for making any changes to the interface based
on changes made to its automated data base. This will
ensure thlt the NPDES State will be held responsible for
system compatibility. If the State does not accept full
responsibility with system compatibility, then changes
muiTnot be made to the State system without the prior
1
all of the time.
-i,isซ2'.tiS
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- 6 -
ปSpnsibility to enter the data into
timely manner.
**-
State ADP system.
ซ106 arant funds may be used for State data entry if and
only if the S?ate ules PCS directly or the State provides
data to PCS via an interface that meets the standards of
this policy.
if reauested bv a State, EPA will agree to pay for its
timesharing costs to imolement this oolicy, within given
resources.
' ซ3ฃSPฃ -i SS^TO^*-^ฐf
*&
Date
Assistant Adrai/lst/ator for Water
r '
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ATTACHMENT 1
REQUIRED DATA TO BE ENTERED INTO PCS
Information Type1
Permit Facility Data
Permit Event Data
Inspection Data
Parameter Limits and
Pipe Schedule Data
Compliance Schedule
Data
DMR Measurement Data
Significant Noncompliance
Flag
Enforcement Action Data
(Enforcement Action Data,
Compliance Schedule Data,
and" Interim Limits Data
from all active fornal
enforcement actions )
Enforcement Action Data
(Type Action, ENAC;
Issue Date, ENDT; and
Date Compliance Required,
ERDT; from all active
formal enforcement
actions)
Pretreatment Approval2
National Municipal Policy
Manors
X
X
X
X
X
X
Minor 92-SOOs
X
X
X
X
X
Other Minors
X
X
X
X
X
lpซr each of the caceaories listed in this chart, the Information
Type II the set of core data elements listed in Attacnment 2.
2Pretreatment Program Required Indicator, PRET; one data element.
ired data as described in May 16, 1985 memorandum on
Sunici-al ^olicy Tracking in PCS. This includes
UsSr Jata Cement 6 (RDF6), Compliance Schedule ana
Enforcement Action information.
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WATER ENFORCEMENT NATIONAL DATA BASE (WENDB) ELEMENTS
Data Element Name
COMMON KEY
NPDES Number
COMPLIANCE SCHEDULE RECORD
Compliance Schedule Number
Data Source Code
Compliance Actual Date
Compliance Report Received Date
Compliance Schedule Date
Compliance Schedule Event Code
COMPLIANCE VIOLATION RECORD
*Compliance Violation Date
*Violation Compliance Event Code
*Gompliance Violation Code
Significant Non-Compliance Code
(Compliance)
Significant Non-Compliance Date
(Compliance) .
Violation Compliance Schedule-
Number
Violation Data Source Coce
ACTION RECORD
Response
Comment Line 1
Comment Line 2
Comment Line 3
Comment Line 4
Comment Line 5
Compliance
Compliance
Modification
Code
Date
Status Code
Response
Status Date
Season Number
Sourcs Code
Discharge
Enforcement Action
Achieved Date
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Action
Violation Code
Enforcement Action
Violation Date
Enforcement Action
Number
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Action
Due Cate
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Action
Numoer
Acronym
NPID
CSCH
DSCD
DTAC
DTRC
DTSC
EVNT
CVDT
CVEV
CVIO
SNCC
SNDC
VCSN
VDC2
EADR
ECMl
ECM2
ECM3
BCM4
EC.M5
ECVC
ECVD
EMOD
ENAC
ENDT
ENST
ERDT
ESDT
ESEA
EVC2
EVDS
y generated oy PCS; can be manually entered
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WENDS ELEMENTS
(Continued)
Data Element Name
Enforcement
Enforcement
Alphabetic
Enforcement
Enforcement
Enforcement
Code
Enforcement
Enforcement
Enforcement
Action Event Code
Action Limit Type-
Action Monitoring Date
Action Monitoring Location
Action STORE! Parameter
Action Discharge Designator
Action Compliance Schedule
Action Violation Type
EVIDENTIARY HEARING RECORD
Evidentiary Hearing Event Date
Evidentiary Hearing Event Code
INSPECTION RECORD
Inspection Date
Inspector Code
Inspection Type
MEASUREMENT VIOLATION RECORD
Measurement Concentration Average
Measurement Concentration Minimum
Measurement Concentration Maximum
Measurement Quantity Average
Measurement Quantity Maximum
Violation Date (Measurement)
No Discharge Indicator
*Significant Non-Compiiance Coae
(Measurement)
*Significant Non-Compliance Date
(Measurement)
Violation Measurement Designator
Measurement Discharge Number
Violation Monitoring Location
Violation STORET Parameter
PARAMETER LIMITS RECORD
.Change of Limit Status
Contested Parameter Indicator
Modification Period End Date
Modification Period Start Date .
Concentration Average Limit
Concentration Minimum Limit
Concentration Maximum Limit
Concentration Unit Cede
Quantity Average Limit
Acronym
EVEV
EVLM '
EVMD
EVML
EVPR
EVRD
EVSN
EVTP
EHDT
EHEV
DTIN
INSP
TYPI
MCAV
MCMN
MCMX
MQAV
MQMX
MVDT
NODI
SNCE
SNDE
VDRD
VDSC
VMLO
VPRM
COLS
CONP
ELED
ELSD
LCAV
LCMN
LCMX
LCUC
LQAV
-------
WENDB ELEMENTS
(Continued}
Data Element Name
Quantity Maximum Limit
Quantity Unit Code
Limit Type - Alphabetic
Monitoring Location
Modification Number
Limit Discharge Number
Limit Report Designator
STORET Parameter Code
Season Number
Statistical Base Code
PERMIT EVENT RECORD
Permit Tracking Actual Date
Permit Tracking Event Code
PERMIT FACILITY RECORD .
River Basin
City Code
County Code
Type Permit Issued - EPA/State
Federal Grant Indicator
Final Limits Indicator
Average Design Flow
Facility Name Long
Facility Inactive Code
Major Discharge Indicator (Enterea
oy EPA Headquarters)
Pretreaocent Program Required
Indicator
SIC Cede
Type Ownership
National Municipal Policy
Tracking Indicator
Significant Noncompliance Flag for
P.L. 92-500 Minor Facilities
PIPE SCHEDULE RECORD
Report Designator
Discharge Numoer
Final Limits End Date
Final Limits Start Date
Inters Limits End Date
Inter is Limits Start pate
Initial Limits End Date
Initial Limits Start Date
Number of Units in Report Perioc
Number of Units in Submission Perioc -
EPA . . .
Number of Units in Submission Period -
State
Acronym
LQMX
LQUC
LTYP
MLOC
MODN
PLDS
PLRD
PRAM
SEAN
STAT
PTAC
PTEV
BAS6
CITY
CNTY
EPST
FDGH
FLIM
FLOW
FNML
IACC
MAD I
PRST
SIC2
TYPO
RDF 6
(To Be Created)
DRID
DSCH
FLED
FLSD
MLE'D
MLSD
ILED
I LSD
NRPU
NSUN
NSUS
-------
WENDB ELEMENTS
(Continued)
Data Element Same
Pipe Inactive Code
Report Units
Initial Report Date
Initial Submission Date
Initial Submission Date
Submission Unit - EPA
Submission Unit - State
State
EPA
Acronym
PIAC
REUN
STRP
STSS
STSU
SUUN
SUUS
NOTE: Additional data elements subject to approval
Frequency of Analysis
Sample Type
Compliance Schedule File Number
Enforcement Action File Number
Permit Limits File Number
Inspection Comments (First
Three Characters for the
Number of Industrial Users
Inspected)
Facility Inactive Date
Reissuance Control Indicator
Pipe Inactive Date
FRAN
SAMP
CSFN
ERFN
LSFN
ICOH
IADD
RCIN
PIDT
Total:
plus additional data elements:
New total:
111 WENDB elements
- 9_ data elements
120 WENDB elements
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC 2 8
OFFICE OF
ENFORCEMENT AND
MEMORANDUM COMPLIANCE ASSURANCE
Subject: ICIS Addendum to the Appendix of the 1985 Permit Compliance System
Policy Statement S r / f"'
From: Michael M. Stahl, DirectotK"'
Office of Compliance /'/ / ,, /
Office of Enforcemenl/arid Compnancfe'Assurance
James A. Hanlon, Director
/ ' ^
Office of Wastewater Management/ ( //''.'
Office of Water i ' '
\
,," i
To: Regional Water Division Directors, Regions 1-10
On October 31, 1985, EPA issued the Permit Compliance System (PCS) Policy
Statement. Since then, the PCS Policy Statement has been updated numerous limes,
including the most recent update in 2000. As of August 2006, 21 states, 2 Tribes and 9
territories have been entering their Clean Water Act National Pollutant Discharge
Elimination System (NPDES) data into the modernized PCS, the Integrated Compliance
Information System for NPDES (ICIS-NPDES). ICIS was designed to incorporate new
technology and the full scope of the NPDES program as it has evolved since 1985. This
Addendum to the PCS Policy Statement provides an interim approach for ensuring
consistency in national NPDES program information during the transition from PCS to
ICIS-NPDES.
The PCS Policy Statement defined a list of data elements, known as the Water
Enforcement National Data Base (WENDB), required to be entered into PCS. This
Addendum specifies the data elements (Attachment 1) in ICIS-NPDES that are
comparable to WENDB. Attachment 1 lists the minimum data that the states, territories,
tribes and EPA Regions using ICIS-NPDES should currently be entering into ICIS.1
The ICIS-NPDES data elements listed in Attachment 1 align as closely as possible to the
universes that are relevant to WENDB as specified in the PCS Policy Statement.
ICIS-NPDES was designed to help states, territories, tribes and EPA Regions implement and manage the
NPDES program in their jurisdictions. Thus, ICIS-NPDES contains many more data elements than the
limited set identified in Attachment 1 for purposes of interim national reporting. We encourage our direct
user states, territories, tribes and the EPA Regions to take advantage of the full functionality and breadth of
the data elements in ICIS-NPDES.
1
ftecyeled/Rocyelable ซ Printed wilh Vegetabte Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
-------
However, given the different system architecture between PCS and ICIS-NPDES, the
ICIS-NPDES data elements listed in Attachment 1 do not correlate to every WENDB
element. Some WENDB data elements do not translate to data elements in ICIS-NPDES;
some were split apart into two data elements in ICIS-NPDES; some were combined in
ICIS-NPDES; and a few were not included in ICIS-NPDES,
For example, in PCS, a Concentrated Animal Feeding Operation (CAFO) permit
could only be signified by a special character in the third digit of the permit number.
ICIS-NPDES allows a CAFO permit to be identified as a unique permit component
for a facility. However, when a particular permit component is identified in ICIS-
NPDES, the system may require additional fields lo be entered. In some situations,
the additional data elements are required to save the permit component record, and in
other cases, additional data elements may be required only when certain activities are
performed for the record to be complete enough to save. In this case, once a facility
is identified as having a CAFO permit component, three additional permit data
elements associated with a CAFO are required by the system to save that entry. If a
CAFO inspection occurs, one additional CAFO-related system-required data element
must be entered before the rest of the inspection record will be saved by the data
system.
Thus, translating WENDB from PCS to ICIS-NPDES is not a direct match. Overall,
while WENDB has 220 data elements, this Addendum (Attachment 1) specifies only 187
data elements that should be entered into ICIS-NPDES during this interim period
This Addendum is necessary to ensure national consistency in minimum data
expectations while the Agency is managing the national NPDES program with both PCS
and ICIS-NPDES. The Agency does not believe that the PCS Policy Statement, even
with this Addendum, meets its national need for information to manage the NPDES
program. Thus, the Agency is concurrently pursuing a rulemaking approach that will
identify a full set of data elements that all implementing agencies of the NPDES program
will be required to enter or otherwise flow to ICIS-NPDES.
The PCS Policy Statement, with this Addendum, continues to be in effect for all agencies
authorized to implement the NPDES program. Agencies that are still using PCS will
continue to follow WENDB, while agencies that have moved from PCS to ICIS will
follow the minimum data elements specified in Attachment 1 to this Addendum. EPA
expects all users of PCS and ICIS-NPDES to maintain the high standards of timeliness,
completeness, and accuracy that have been expected in PCS,
If you have questions regarding this Addendum, you may contact Betsy Smidinger,
Deputy Division Director, Enforcement Targeting and Data Division, at (202) 564-4017.
The staff contact is Andy Hudock at (202) 564-6032
cc: ICIS-NPDES and PCS Coordinators in States and Regions
Expanded ICIS-NPDES/PCS Steering Committee
Attachment
-------
ง123.45
40 CFR Ch. I (7-1-08 Edition)
(f) A public hearing held under para-
graph (e) of this section shall be con-
ducted by the Regional Administrator,
and, at the Regional Administrator's
discretion, with the assistance of an
EPA panel designated by the Regional
Administrator, in an orderly and expe-
ditious manner.
(g) Following the public hearing, the
Regional Administrator shall reaffirm
the original objection, modify the
terms of the objection, or withdraw the
objection, and shall notify the State of
this decision.
(h)(l) If no public hearing is held
under paragraph (e) of this section and
the State does not resubmit a permit
revised to meet the Regional Adminis-
trator's objection within 90 days of re-
ceipt of the objection, the Regional Ad-
ministrator may issue the permit in
accordance with parts 121, 122 and 124
of this chapter and any other guide-
lines and requirements of CWA.
(2) If a public hearing is held under
paragraph (e) of this section, the Re-
gional Administrator does not with-
draw the objection, and the State does
not resubmit a permit revised to meet
the Regional Administrator's objection
or modified objection within 30 days of
the date of the Regional Administra-
tor's notification under paragraph (g)
of this section, the Regional Adminis-
trator may issue the permit in accord-
ance with parts 121, 122 and 124 of this
chapter and any other guidelines and
requirements of CWA.
(3) Exclusive authority to issue the
permit passes to EPA when the times
set out in this paragraph expire.
(i) [Reserved]
(j) The Regional Administrator may
agree, in the Memorandum of Agree-
ment under ง123.24 (or, in the case of a
sewage sludge management program,
ง501.14 of this chapter), to review draft
permits rather than proposed permits.
In such a case, a proposed permit need
not be prepared by the State and trans-
mitted to the Regional Administrator
for review in accordance with this sec-
tion unless the State proposes to issue
a permit which differs from the draft
permit reviewed by the Regional Ad-
ministrator, the Regional Adminis-
trator has objected to the draft permit,
or there is significant public comment.
[48 FR 14178, Apr. 1, 1983, as amended at 54
FR 18785, May 2, 1989; 54 FR 23896, June 2,
1989; 60 FR 15386, Mar. 23, 1995; 63 FR 45122,
Aug. 24, 1998; 65 FR 30910, May 15, 2000]
ง 123.45 Noncompliance and program
reporting by the Director.
The Director shall prepare quarterly,
semi-annual, and annual reports as de-
tailed below. When the State is the per-
mit-issuing authority, the State Direc-
tor shall submit all reports required
under this section to the Regional Ad-
ministrator, and the EPA Region in
turn shall submit the State reports to
EPA Headquarters. When EPA is the
permit-issuing authority, the Regional
Administrator shall submit all reports
required under this section to EPA
Headquarters.
(a) Quarterly reports. The Director
shall submit quarterly narrative re-
ports for major permittees as follows:
(1) Format. The report shall use the
following format:
(i) Provide a separate list of major
NPDES permittees which shall be sub-
categorized as non-POTWs, POTWs,
and Federal permittees.
(ii) Alphabetize each list by per-
mittee name. When two or more per-
mittees have the same name, the per-
mittee with the lowest permit number
shall be entered first.
(ill) For each permittee on the list,
include the following information in
the following order:
(A) The name, location, and permit
number.
(B) A brief description and date of
each instance of noncompliance for
which paragraph (a)(2) of this section
requires reporting. Each listing shall
indicate each specific provision of
paragraph (a)(2) (e.g., (ii)(A) thru
(iii)(G)) which describes the reason for
reporting the violation on the quar-
terly report.
(C) The date(s), and a brief descrip-
tion of the action(s) taken by the Di-
rector to ensure compliance.
(D) The status of the instance(s) of
noncompliance and the date non-
compliance was resolved.
(E) Any details which tend to explain
or mitigate the instance(s) of non-
compliance.
260
-------
Environmental Protection Agency
ง123.45
(2) Instances of noncompliance by major
dischargers to be reported(i) General.
Instances of noncompliance, as defined
in paragraphs (a)(2)(ll) and (ill) of this
section, by major dischargers shall be
reported in successive reports until the
noncompliance is reported as resolved
(i.e., the permittee is no longer vio-
lating the permit conditions reported
as noncompliance in the QNCR). Once
an instance of noncompliance is re-
ported as resolved in the QNCR, it need
not appear in subsequent reports.
(A) All reported violations must be
listed on the QNCR for the reporting
period when the violation occurred,
even if the violation is resolved during
that reporting period.
(B) All permittees under current en-
forcement orders (i.e., administrative
and judicial orders and consent de-
crees) for previous instances of non-
compliance must be listed in the QNCR
until the orders have been satisfied in
full and the permittee is in compliance
with permit conditions. If the per-
mittee is in compliance with the en-
forcement order, but has not achieved
full compliance with permit condi-
tions, the compliance status shall be
reported as "resolved pending," but the
permittee will continue to be listed on
the QNCR.
(ii) Category I noncompliance. The fol-
lowing instances of noncompliance by
major dischargers are Category I non-
compliance:
(A) Violations of conditions in en-
forcement orders except compliance
schedules and reports.
(B) Violations of compliance schedule
milestones for starting construction,
completing construction, and attaining
final compliance by 90 days or more
from the date of the milestone speci-
fied in an enforcement order or a per-
mit.
(C) Violations of permit effluent lim-
its that exceed the Appendix A "Cri-
teria for Noncompliance Reporting in
the NPDES Program".
(D) Failure to provide a compliance
schedule report for final compliance or
a monitoring report. This applies when
the permittee has failed to submit a
final compliance schedule progress re-
port, pretreatment report, or a Dis-
charge Monitoring Report within 30
days from the due date specified in an
enforcement order or a permit.
(ill) Category II noncompliance. Cat-
egory II noncompliance includes viola-
tions of permit conditions which the
Agency believes to be of substantial
concern and may not meet the Cat-
egory I criteria. The following are in-
stances of noncompliance which must
be reported as Category II noncompli-
ance unless the same violation meets
the criteria for Category I noncompli-
ance:
(A) (1) Violation of a permit limit;
(2) An unauthorized bypass;
(3) An unpermitted discharge; or
(4) A pass-through of pollutants
which causes or has the potential to
cause a water quality problem (e.g.,
fish kills, oil sheens) or health prob-
lems (e.g., beach closings, fishing bans,
or other restrictions of beneficial uses).
(B) Failure of an approved POTW to
implement its approved pretreatment
program adequately including failure
to enforce industrial pretreatment re-
quirements on industrial users as re-
quired in the approved program.
(C) Violations of any compliance
schedule milestones (except those mile-
stones listed in paragraph (a)(2)(ll)(B)
of this section) by 90 days or more from
the date specified in an enforcement
order or a permit.
(D) Failure of the permittee to pro-
vide reports (other than those reports
listed in paragraph (a)(2)(ll)(D) of this
section) within 30 days from the due
date specified in an enforcement order
or a permit.
(E) Instances when the required re-
ports provided by the permittee are so
deficient or incomplete as to cause
misunderstanding by the Director and
thus impede the review of the status of
compliance.
(F) Violations of narrative require-
ments (e.g., requirements to develop
Spill Prevention Control and Counter-
measure Plans and requirements to im-
plement Best Management Practices),
which are of substantial concern to the
regulatory agency.
(G) Any other violation or group of
permit violations which the Director or
Regional Administrator considers to be
of substantial concern.
(b) Semi-annual statistical summary re-
port. Summary information shall be
261
-------
ง123.45
40 CFR Ch. I (7-1-08 Edition)
provided twice a year on the number of
major permittees with two or more vio-
lations of the same monthly average
permit limitation in a six month pe-
riod, including those otherwise re-
ported under paragraph (a) of this sec-
tion. This report shall be submitted at
the same time, according to the Fed-
eral fiscal year calendar, as the first
and third quarter QNCRs.
(c) Annual reports for NPDES(1) An-
nual noncompliance report. Statistical
reports shall be submitted by the Di-
rector on nonmajor NPDES permittees
indicating the total number reviewed,
the number of noncomplying nonmajor
permittees, the number of enforcement
actions, and number of permit modi-
fications extending compliance dead-
lines. The statistical information shall
be organized to follow the types of non-
compliance listed in paragraph (a) of
this section.
(2) A separate list of nonmajor dis-
charges which are one or more years
behind in construction phases of the
compliance schedule shall also be sub-
mitted in alphabetical order by name
and permit number.
(d) Schedule(1) For all quarterly re-
ports. On the last working day of May,
August, November, and February, the
State Director shall submit to the Re-
gional Administrator information con-
cerning noncompliance with NPDES
permit requirements by major dis-
chargers in the State in acordance with
the following schedule. The Regional
Administrator shall prepare and sub-
mit information for EPA-issued per-
mits to EPA Headquarters in accord-
ance with the same schedule:
QUARTERS COVERED BY REPORTS ON
NONCOMPLIANCE BY MAJOR DISCHARGERS:
[Date for completion of reports]
January, February, and March 1 May 31
April, May, and June 1 August 31
July, August, and September 1 November 30
October, November, and Decem- 1 February 28
ber.
1 Reports must be made available to the public for inspec-
tion and copying on this date.
(2) For all annual reports. The period
for annual reports shall be for the cal-
endar year ending December 31, with
reports completed and available to the
public no more than 60 days later.
APPENDIX A TO ง123.45CRITERIA FOR NON-
COMPLIANCE REPORTING IN THE NPDES PRO-
GRAM
This appendix describes the criteria for re-
porting violations of NPDES permit effluent
limits in the quarterly noncompliance report
(QNCR) as specified under ง123.45(a)(2)(ii)(c).
Any violation of an NPDES permit is a viola-
tion of the Clean Water Act (CWA) for which
the permittee is liable. An agency's decision
as to what enforcement action, if any, should
be taken in such cases, will be based on an
analysis of facts and legal requirements.
Violations of Permit Effluent Limits
Cases in which violations of permit efflu-
ent limits must be reported depend upon the
magnitude and/or frequency of the violation.
Effluent violations should be evaluated on a
parameter-by-parameter and outfall-by-out-
fall basis. The criteria for reporting effluent
violations are as follows:
a. Reporting Criteria for Violations of
Monthly Average Permit LimitsMag-
nitude and Frequency
Violations of monthly average effluent
limits which exceed or equal the product of
the Technical Review Criteria (TRC) times
the effluent limit, and occur two months in
a six month period must be reported. TRCs
are for two groups of pollutants.
Group I PollutantsTRC=1.4
Group II PollutantsTRC=1.2
b. Reporting Criteria for Chronic Violations
of Monthly Average Limits
Chronic violations must be reported in the
QNCR if the monthly average permit limits
are exceeded any four months in a six-month
period. These criteria apply to all Group I
and Group II pollutants.
GROUP I POLLUTANTSTRC=1.4
Oxygen Demand
Biochemical Oxygen Demand
Chemical Oxygen Demand
Total Oxygen Demands
Total Organic Carbon
Other
Solids
Total Suspended Solids (Residues)
Total Dissolved Solids (Residues)
Other
Nutrients
Inorganic Phosphorus Compounds
Inorganic Nitrogen Compounds
Other
Detergents and Oils
MB AS
262
-------
Environmental Protection Agency
ง123.46
NTA
Oil and Grease
Other detergents or algicides
Minerals
Calcium
Chloride
Fluoride
Magnesium
Sodium
Potassium
Sulfur
Sulfate
Total Alkalinity
Total Hardness
Other Minerals
Metals
Aluminum
Cobalt
Iron
Vanadium
GROUP II POLLUTANTSTRC=1.2
METALS (ALL FORMS)
Other metals not specifically listed under
Group I
Inorganic
Cyanide
Total Residual Chlorine
Organics
All organics are Group II except those spe-
cifically listed under Group I.
(Approved by the Office of Management and
Budget under control number 2040-0082)
[48 FR 14178, Apr. 1, 1983, as amended at 50
FR 34653, Aug. 26, 1985; 54 FR 18785, May 2,
1989; 63 FR 45123, Aug. 24, 1998]
ง 123.46 Individual control strategies.
(a) Not later than February 4, 1989,
each State shall submit to the Re-
gional Administrator for review, ap-
proval, and Implementation an Indi-
vidual control strategy for each point
source Identified by the State pursuant
to section 304(1)(1)(C) of the Act which
discharges to a water Identified by the
State pursuant to section 304(1)(1)(B)
which will produce a reduction In the
discharge of toxic pollutants from the
point sources Identified under section
304(1)(1)(C) through the establishment
of effluent limitations under section
402 of the CWA and water quality
standards under section 303(c)(2)(B) of
the CWA, which reduction Is sufficient,
In combination with existing controls
on point and nonpolnt sources of pollu-
tion, to achieve the applicable water
quality standard as soon as possible,
but not later than three years after the
date of establishment of such strategy.
(b) The Administrator shall approve
or disapprove the control strategies
submitted by any State pursuant to
paragraph (a) of this section, not later
than June 4, 1989. If a State falls to
submit control strategies In accord-
ance with paragraph (a) of this section
or the Administrator does not approve
the control strategies submitted by
such State In accordance with para-
graph (a), then, not later than June 4,
1990, the Administrator In cooperation
with such State and after notice and
opportunity for public comment, shall
Implement the requirements of CWA
section 304(1)(1) In such State. In the
Implementation of such requirements,
the Administrator shall, at a min-
imum, consider for listing under CWA
section 304(1)(1) any navigable waters
for which any person submits a peti-
tion to the Administrator for listing
not later than October 1, 1989.
(c) For the purposes of this section
the term Individual control strategy,
as set forth In section 304(1) of the
CWA, means a final NPDES permit
with supporting documentation show-
Ing that effluent limits are consistent
with an approved wasteload allocation,
or other documentation which shows
that applicable water quality standards
will be met not later than three years
after the Individual control strategy Is
established. Where a State Is unable to
Issue a final permit on or before Feb-
ruary 4, 1989, an Individual control
strategy may be a draft permit with an
attached schedule (provided the State
meets the schedule for Issuing the final
permit) Indicating that the permit will
be Issued on or before February 4, 1990.
If a point source Is subject to section
304(1)(1)(C) of the CWA and Is also sub-
ject to an on-slte response action under
sections 104 or 106 of the Comprehen-
sive Environmental Response, Com-
pensation, and Liability Act of 1980
(CERCLA), (42 U.S.C. 9601 et seq.), an
Individual control strategy may be the
decision document (which Incorporates
the applicable or relevant and appro-
priate requirements under the CWA)
prepared under sections 104 or 106 of
CERCLA to address the release or
263
-------
-------
ICIS-NPDES Policy Statement
Table
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
of Contents
Introduction
Relationship of this ICIS-NPDES Policy Statement to the PCS
Policy Statement (as revised since issuance in October 1985)
RIDE and Key Data Groupings
Efficient Options to Provide Data into ICIS-NPDES
ICIS-NPDES Data Entry Expectations
Data Entry Targets for National Consistency
Development and Implementation of Transition Plans
Additional Operational Activities
Policy Revision and Relationship to Other Policies
Appendices
1 . RIDE by Data Area and Program Area
2a. Detailed RIDE Table for States, Territories, Tribes and Regions
2b. Additional Federal-only RIDE table for Regions
3 . RIDE Data Entry Considerations by Program Area
3a. Revised EPA RIDE Data Entry Model
4. Key National Targets for Data in ICIS-NPDES
5. Template for a Transition Plan
6 Roles and Responsibilities
7. Definitions of Terms and Acronyms
a. Terms
b. Acronyms
Page
1
3
3
5
7
10
12
13
14
ICIS-NPDES Policy Statement ii April 30,2007 draft
-------
A. Introduction
The U.S. Environmental Protection Agency (EPA) has the primary responsibility
to ensure that the Clean Water Act's (CWA) National Pollutant Discharge Elimination
System (NPDES) program is effectively and consistently implemented across the
country. In order for EPA to manage the NPDES national program, EPA needs ready
access to information on the facilities that are regulated by the NPDES program. Some
of EPA's national NPDES information needs are described below:
Timely access to facility-specific permit, discharge, compliance and
enforcement information in a nationally consistent format is critical for EPA
to 1) develop effective regulations, such as national effluent guidelines for
specific industrial sectors, 2) identify non-compliance problems, trends, and
their associated environmental impacts on both an intra-state and inter-state
basis, and 3) develop effective national strategies for improving compliance
and environmental protection.
EPA needs information to demonstrate results achieved by effectively using
resources to meet NPDES program goals, including the Government
Performance and Results Act (GPRA) measures reported to Congress. Under
this Act, EPA and other agencies are required to develop long-range Strategic
Plans, Annual Performance Plans with measures and targets, and Annual
Performance Reports describing how well targets are met.1 OMB is now
linking Agency budgets, including funding for State grants, directly to each
program's strategic plans and targets.
EPA needs facility-specific data to inform the Program Assessment Rating
Tool (PART) process, which is now used to assess 20% of all Federal
programs each year. In combination, GPRA and PART require EPA to align
program activities to annual performance plans, clarify organizational
expected outcomes, manage outcomes rather than inputs and activities, and
design measurement systems that accurately track results. In the PART
process, OMB evaluates performance in program purpose and design,
strategic planning, program management, and program results and
accountability. State and Federal funding levels, including State grants, in the
President's budget are now linked to PART and have been significantly
impacted by the PART rating.
1 Examples of GPRA measures for the NPDES program include tracking of schedules for combined sewer
overflow (CSO) long-term control plans; percent of permits that are current; percent of scheduled high-
priority permits that are current; number of facilities covered by storm water permits for municipalities
(MS4s) and for construction; percent of concentrated animal feeding operations (CAFOs) covered by an
NPDES permit; percent of significant industrial users (SIUs) in publicly-owned treatment works (POTWs)
with pretreatment programs that implement applicable pretreatment requirements; and percent of known
categorical industrial users in non-pretreatment POTWs that have control mechanisms that cover
pretreatment requirements.
ICIS-NPDES Policy Statement 1 April 30,2007 draft
-------
EPA needs detailed information for its program oversight responsibilities. For
example, Permitting for Environmental Results (PER) was established to
analyze how the NPDES programs could improve integrity, efficiency, and
environmental results in the face of declining resources, increasing backlogs,
expansion of the NPDES program, and third-party petitions and lawsuits to
withdraw NPDES Programs. Another example, the State Review Framework
process is used to ensure minimum national consistency in State NPDES
compliance and enforcement programs.
EPA responds to frequent NPDES inquiries from various Congressional
members, regarding certain facilities, companies, or activities that may be
national in scope, particularly in conjunction with oversight hearings,
requiring immediate access to multi-State, facility-specific data on particular
pollutant discharges.
In the past, EPA primarily obtained this information from the Permit Compliance
System (PCS). Since 1985, PCS served as the official national information system used
for management of the NPDES program. The NPDES program has evolved considerably
since the creation of PCS. In recent years, there has been an increasing realization,
confirmed by State water quality reports, that, in addition to traditional major sources,
smaller and/or non-traditional sources also contribute significantly to the pollution of our
nation's waters. These smaller and non-traditional sources include facilities in particular
program areas such as biosolids, concentrated animal feeding operations (CAFOs),
combined sewer systems (CSSs), separate sanitary sewer systems (SSSs), stormwater and
pretreatment.
The evolution of the NPDES program since the inception of PCS has created an
increasing need to better reflect a more complete picture of the NPDES program and the
diverse universe of regulated sources. PCS no longer meets the national needs of EPA to
manage the NPDES program and no longer meets the NPDES program needs of
individual States that use PCS to implement the NPDES program in their States.
During the past several years, EPA has worked closely with its State partners in
an effort to modernize PCS as an NPDES component of EPA's existing Integrated
Compliance Information System (ICIS). To accurately reflect the NPDES program,
ICIS-NPDES was designed to include data and functionality for the full breadth of the
NPDES program for a variety of permit types and program areas.
This Policy Statement describes the essential information (defined as the
Requisite ICIS-NPDES Data Elements [RIDE]) EPA needs nationally to effectively
manage the national NPDES program. These RIDE and the information that they
represent are also essential to the individual permitting authorities for effective
implementation and enforcement of the NPDES program.
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This ICIS-NPDES Policy Statement establishes ICIS-NPDES as the database of
record for the national NPDES program and seeks to ensure that ICIS-NPDES contains
accurate, complete, consistent, and timely information, in accordance with the Data Entry
Protocols specified in Section E.I. of this Policy Statement. Through implementation of
this Policy Statement, EPA can effectively manage the NPDES national program to
ensure that the human health and environmental protection goals of the CWA are met.
This Policy Statement does not substitute for any CWA statutory provisions or EPA
regulations and is intended as guidance pursuant to applicable regulations (e.g., 40
CFRง123.41(a)) .
B. Relationship of this ICIS-NPDES Policy Statement to the PCS Policy
Statement (as revised since issuance in October 1985)
The PCS Policy Statement (issued in October 19852 and later revised) remains the
Agency policy for use of PCS for those States, Territories and Tribes currently using or
transferring data into PCS. The States, Territories and Tribes currently transferring data
into PCS should review this ICIS-NPDES Policy Statement as certain steps should be
taken now for a successful transition from PCS to ICIS-NPDES. As set forth in Section
G, the transition plans for hybrid and non-direct (batch) users of ICIS-NPDES are
intended to address this need for advance planning.
As a State, Territory or Tribe moves into ICIS-NPDES (whether as a direct user,
hybrid user or as a non-direct user) and data is entered directly or is made available for
batch transfer into ICIS-NPDES, the data entry roles, activities and responsibilities of that
permitting authority are covered by this ICIS-NPDES Policy Statement. Water
Enforcement National Data Base (WENDB) is the minimum required data when using
PCS; Requisite ICIS-NPDES Data Elements (RIDE) have been identified as the
minimum data that should be available in ICIS-NPDES.
C. RIDE and Key Data Groupings
This Policy Statement designates the specific set of data elements that are
essential for EPA to effectively manage the national NPDES program. These data
elements are the Requisite ICIS-NPDES Data Elements or RIDE for ICIS-NPDES. EPA
has consulted with States and Regions extensively in developing and refining RIDE. In
FY 2002, EPA and State staff and managers identified the data needed to successfully
implement and manage the NPDES program. Their recommendations were discussed by
the State and EPA members of the PCS Steering Committee, and subsequently adopted
2 As issued in 1985, the PCS Policy Statement specified that: 1) PCS would be the national data base of
record for the NPDES program; 2) the EPA Regions must use PCS directly; and 3) all NPDES authorized
States must either use PCS directly or develop and maintain an interface that transfers the State's data to
PCS. The PCS Policy Statement further defined the minimum required data necessary to enable PCS to
function as a useful operational and management tool for the NPDES program; in PCS, this list of
minimum required data was called WENDB.
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by the PCS Modernization Executive Council as the first draft of what later came to be
called RIDE.
EPA sought additional state input into RIDE and the development of this Policy
Statement by expanding the Steering Committee to add representatives from the
Environmental Council of States (ECOS) and the Association of State and Interstate
Water Pollution Control Administrators (ASIWPCA). In 2006 and 2007, this Expanded
Steering Committee held three face-to-face meetings, conducted numerous conference
calls, and created several workgroups. Based on those efforts, EPA has made significant
reductions in the initial RIDE list and other revisions to reduce the data entry burden.
RIDE can be grouped into four main data areas and several data sub-areas, as
identified in Table 1 below.
Table 1: RIDE Overview by Data Areas
ICIS-NPDES
Data Area
Facility
Permit
Compliance
Monitoring
Enforcement
Sub- Areas
Basic Information, Contacts,
Addresses, Latitude, Longitude
Basic Information, Narrative
Condition, Permit Schedule, Permitted
Feature, Limit
Inspections
Discharge Monitoring Reports
(DMRs)
Violations
Basic Information, Milestones,
Sub -activities, Final Orders, Penalties,
Compliance Schedules
Customary
Entry
Frequency
Once
(updated if
necessary)
Once/
permit cycle
Once/ year
or less
Once/
month/ limit
As they
occur
As they
occur
Additional
Permit
Component
Information
None
Biosolids,
CAFOs,
CSSs, SSSs,
Stormwater,
Pretreatment
None
The data element organization shown in Table 1 is reflected in Appendix 1, which
is a chart that identifies how many RIDE are associated with each data area. For
example, Appendix 1 indicates that there are 25 RIDE associated with facility data, 82
RIDE associated with permitting data, 125 RIDE associated with special program areas,
and 53 RIDE associated with compliance monitoring and enforcement.
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Appendix 1 also indicates that, of the 285 RIDE3 to be entered or transferred into
ICIS-NPDES by permitting authorities, 43 are conditional in that data entry or transfer is
only expected under rare circumstances or if another RIDE is entered with a particular
code. An example of such a conditional RIDE would be "Animal: Other" in the CAFO
component sub-area of RIDE permit information; this data element would only be
necessary if the entry of the RIDE "Animal: Type" (also in the CAFO component sub-
area of permit information) was answered with something other than one of the animal
types listed in the "drop-down menu" of the data entry screen in ICIS-NPDES.
A detailed list of all 285 RIDE, with columns providing information regarding
data element descriptions, equivalent data elements in PCS, permit types for which that
data element is needed, and comments is provided in Appendix 2a. Appendix 2a also
identifies each of the 43 conditional RIDE by means of shaded rows on the table.
For a specific facility, not all of the 285 RIDE are likely to apply. The number of
RIDE that will apply to a particular NPDES facility will vary based on facility-specific
factors, such as the type of permit(s), the activities undertaken by the State, Territory,
Tribe or EPA at the facility (e.g., inspections, enforcement actions), and the particular
operations and processes engaged in by the facility in the particular program area (e.g.,
biosolids, CAFOs, CSSs, SSSs, stormwater and pretreatment). Appendix 3 describes the
data entry considerations for various special program areas; Appendix 3a indicates the
estimated data entry resources for various program areas and permit types.
As Table 1 indicates, the frequency of data entry for RIDE will vary depending on
the type of data. Many data elements are entered once (e.g., those associated with facility
identification); permit specific information is usually entered only once every five years;
Discharge Monitoring Reports (DMRs) are generally entered monthly; inspection,
violations and enforcement data are entered only if or as those activities occur. Some
other data elements are system-generated for direct users. In addition, in an effort to
reduce the resource burden of ICIS-NPDES startup, EPA is working with the individual
States, Territories or Tribes to ensure that existing facility, permit, compliance
monitoring and enforcement data is migrated from PCS to ICIS-NPDES.
D. Efficient Options to Provide Data into ICIS-NPDES
ICIS-NPDES is a user-friendly system, providing desktop access, real-time data
and powerful reporting tools. ICIS-NPDES utilizes new technology and promotes
integrated processing of information. Two efficient methods for States, Territories and
Tribes to provide EPA with RIDE are through:
3 An additional 27 RIDE are required for data entry into ICIS-NPDES by EPA Regions for Federal
activities (e.g., inspections, enforcement actions) and for non-authorized States, Territories and Tribes for
which the Region is manually entering RIDE. See Appendix 2b for a list of these additional Federal-only
RIDE.
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direct data entry via user-friendly web interfaces, with point and click features
and drop down menus, including easy-to-use DMR data entry screens; and,
batch transferring of data, using approved ICIS-NPDES XML schema, via the
Agency's Central Data Exchange (CDX) portal and the National Environmental
Information Exchange Network, and possible utilization of an electronic DMR
tool, such as NetDMR for facilities.
Data transfer to ICIS-NPDES is expected to be seamless and transparent. EPA
recognizes that some States, Territories or Tribes may use both methods of data entry,
depending on the type of data and their own needs. Because consistent and objective
compliance tracking is a central component of an effective and credible enforcement
program, States, Territories and Tribes are encouraged to use ICIS-NPDES directly as a
primary management system for their NPDES programs. (EPA Regions are required to
directly use ICIS-NPDES.)
However, because some States already have their own NPDES databases and plan
to continue using them to manage the program, these States may batch transfer data to
ICIS-NPDES. EPA is working with non-direct-user (batch) States through an Integrated
Project Team (IPT) to develop, test and implement the batch transfer of RIDE to
ICIS-NPDES. Batch transfer programs from States, Territories and Tribes should
conform to EPA Central Data Exchange procedures and should use approved ICIS-
NPDES XML schema formats.
EPA has provided grants to assist States in making the transition from PCS to
ICIS-NPDES. For example, during FY 2004-2005, ICIS-NPDES was addressed in
13 Exchange Network grants to facilitate batch information exchange from States that are
not direct users of ICIS-NPDES. During that same period, EPA's Office of Enforcement
and Compliance Assurance (OECA) also provided 21 grants totaling $3.57 million in
preparations at the State level to migrate data from PCS into ICIS-NPDES or to otherwise
transition into ICIS-NPDES.
The RIDE Data Entry Estimate Model developed in association with the
Expanded Steering Committee has estimated that over 90% of RIDE data entry resources
are associated with data entry of DMRs. To maximize efficiencies realized already by
some States, EPA encourages States, Territories and Tribes to pursue electronic reporting
of DMR data directly by permitted facilities. Electronic DMR submission (verification,
authentication, and authorization) should be consistent with the Agency's requirements
set forth in the Cross-Media Electronic Reporting Final Rule (Federal Register.,
October 13, 2005).
EPA is working with States to create a national tool (NetDMR) to support
electronic reporting of DMR data directly from facilities to the permitting authority, a
feature that will dramatically reduce the cost of entering DMR data into ICIS-NPDES as
well as into State information systems. Electronic reporting of DMR data will increase
the quality and amount of DMR data available, while leading to reduced manual data
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entry costs. This will improve implementation and management of the NPDES program
by increasing the available effluent data that states and EPA can use to identify and target
compliance and environmental problems. As many as 20 States are developing electronic
DMR reporting systems or have applied for EPA grants to develop such systems, and a
handful of States have already implemented online electronic DMR reporting tools.
E. ICIS-NPDES Data Entry Expectations
1. Data Entry Protocols
Once a State, Territory, Tribe or EPA begins using ICIS-NPDES, they are expected to
follow data entry, timeliness and quality protocols that govern EPA data. EPA may
assess these protocols on a regular basis. In summary, all data entered or batched into
ICIS-NPDES should be:
Timely: Data for a State, Territory or Tribe should be entered or batched into
ICIS-NPDES within 30 days of the event/action. For EPA Regions, data for
inspections, single event violations, and enforcement actions should be entered
into ICIS-NPDES within 14 days; Regions should enter permit limits, permit limit
sets, DMRs and other RIDE into ICIS-NPDES within 30 days of receipt. Timely
data is critical because ICIS-NPDES provides "real time" data for use and
analysis. In addition, some of this data is accessible to the public through ECHO
and Envirofacts.
Accurate: The design of ICIS-NPDES, with "drop-down" menu lists, standard
Oracle data validation checks, data standards and ICIS-NPDES XML schema will
greatly reduce data entry errors. RIDE data should be identical with that reported
on the DMR, permit or other input document.
Complete: Reporting of RIDE ensures that all necessary information is available
for the purposes of program management, oversight and reporting. This
ICIS-NPDES Policy Statement establishes an overall goal of at least 98%
completeness for data entry and, in the appendices to this document, describes
other targets related to data completeness during the transition period (such as
interim national data targets for DMR data entry for non-major facilities).
Consistent: Data needs to be comparable for use in national and interstate
watershed analyses and the ICIS-NPDES system design incorporates the Agency
Data Standards requirements to provide consistent standards for reporting. To
ensure national consistency, batch transfer programs from States and Tribes
should conform to EPA Central Data Exchange procedures and should use
approved ICIS-NPDES XML schema formats.
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2. "Prospective" Entry/Availability of Non-WENDB Data
For those RIDE that were not WENDB data elements in PCS, data
entry/availability of RIDE in ICIS-NPDES should be "prospective" in nature. That is,
the RIDE data entry or transfer into ICIS-NPDES for these particular elements should be
completed from some date forward (in accordance with approved transition plans, as
described in Sections F and G) without a need to enter old data. One caveat to this rule
occurs in the case of new enforcement actions addressing violations that are not already
in the system; EPA expects violation (and any relevant inspection) information associated
with these actions to be entered into ICIS-NPDES with the enforcement actions.
3. Few Data Entry Distinctions between Majors and Non-Majors
In PCS, some WENDB data elements apply to every facility regardless of its
permit type; other WENDB data elements in PCS apply just to major facilities. However,
in ICIS-NPDES, unlike PCS, few distinctions in data entry expectations for RIDE have
been made between major facilities and non-major facilities. Exceptions include the
"phased-in" data entry of DMRs, associated limits, and limit sets for non-majors (as
described above), and distinctions for some program areas, as described below and in
Appendix 3, which provides a brief synopsis for each program area.
4. Appropriate Linkages in ICIS-NPDES
Appropriate linkages between the data for compliance monitoring, violations and
enforcement items should be entered into ICIS-NPDES. For example, an inspection
should be linked to all violations identified during the inspection, which in turn should be
linked to any resulting enforcement action, penalty or compliance schedule. In addition,
the information for an unpermitted facility which subsequently becomes a permittee
could be linked in ICIS-NPDES.
5. Violation Tracking
The automatic tracking function in ICIS-NPDES for DMR non-receipt and other
violations (e.g., compliance schedule) will be "turned on" for both majors and
non-majors. For non-major permits, this can be "turned off during the transition period
(described in Section G) and turned back on as DMR entry begins for those facilities, but
no later than the final expected data entry date listed in that State's or Tribe's transition
plan (also described in Section F). This will allow EPA, States and Tribes to obtain the
full benefit of automatic tracking of these violations and makes effective use of the
resources allocated to data collection and data entry. In addition, such tracking may be
ICIS-NPDES Policy Statement 8 April 30,2007 draft
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very beneficial to automate NPDES reporting requirements such as the Annual
Non-Compliance Report for NPDES Non-Majors required by 40 CFR ง123.45 (c).
6. Significant Industrial Users in Non-Pretreatment Cities
RIDE data on specific Significant Industrial Users (SIUs) are only expected in
ICIS-NPDES if the pretreatment control authority is EPA, the State, the Territory, or the
Tribal permitting authority, rather than a municipal treatment facility implementing an
approved local pretreatment program. However, States, Territories, Tribes and Regions
could use ICIS-NPDES to track additional SIUs, if so inclined.
7. Stormwater Construction Sites
For the large universe of Stormwater construction sites, RIDE should be entered
or transferred into ICIS-NPDES for States, Territories and Tribes if the State, Territory or
Tribe issues the facility (whether Phase I or Phase II) a formal enforcement action, an
administrative penalty order, or an informal enforcement action (but only if the informal
enforcement action addresses significant non-compliance [SNC]4 under that construction
site permit). In such circumstances, RIDE should be entered or transferred into
ICIS-NPDES for the facility information and permit information for that site (if not
already available in ICIS-NPDES), the enforcement action, penalty or compliance
schedule, and all inspections and associated identified violations which precipitated that
enforcement action. As indicated in Appendix 4, these enforcement actions, inspections,
and all other RIDE for Stormwater construction sites should begin to entered or
transferred into ICIS-NPDES as they occur effective August 1, 2007, or within four
months after migration to ICIS-NPDES. For all other Stormwater construction sites, data
from DMRs, associated limits and limit sets need not be entered into ICIS-NPDES.
For EPA Regions, RIDE for all Stormwater construction inspections performed by
the Regions and all resulting enforcement actions by the Regions are expected to be
entered into ICIS-NPDES and linked appropriately. In order to enter RIDE data into
ICIS-NPDES, the facility information and permit information for that site will have to be
entered into ICIS-NPDES by the Region (if such information is not already available in
ICIS-NPDES).
8. Satellite Collection Systems to Separate Sanitary Sewer Systems (SSSs): Other
Unpermitted Facilities
The ICIS 2.0 Users Guide (Permits section) states that: "Unpermitted facilities are
records established in ICIS to allow for tracking of activities (e.g., inspections and
4 Significant non-compliance (SNC) for Stormwater construction sites and which informal enforcement
actions will address such SNC will be defined in the wet weather SNC guidance, currently under
development by EPA.
ICIS-NPDES Policy Statement 9 April 30,2007 draft
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enforcement actions) that are associated with facilities that do not have [NPDES] permits.
They may not contain narrative conditions, schedules, or limits."
RIDE data entry is not expected for those portions of a State program that are
"broader in scope" than the approved NPDES program (under 33 U.S.C. ง 1342(b)). In
general (except for SIUs in non-pretreatment cities), RIDE data are expected to be
entered into ICIS-NPDES for unpermitted facilities only if the facility has been issued a
formal enforcement action, an administrative penalty order, or an informal enforcement
action (but only if the informal enforcement action addresses significant non-compliance,
or if the facility should have a NPDES permit. In such situations, the facility RIDE and
permit RIDE (if any) should be entered into ICIS-NPDES before the compliance
monitoring, violation and enforcement information can be entered and appropriately
linked.
For example, for SSS satellite systems, RIDE should be entered if the SSS
satellite system receives a formal enforcement action, an administrative penalty order, or
an informal enforcement action (but only if the informal enforcement action addresses the
SSS significant non-compliance [SNC]5). In such circumstances, RIDE should be
entered for the facility information and permit information (if any) for that site, the
enforcement action, penalty or compliance schedule, and all inspections and identified
violations which precipitated that enforcement action.
F. Data Entry Targets for National Consistency
EPA expects that there will be a transition period (described in Section G) as
States become acclimated to ICIS-NPDES as a new information system. In addition,
EPA recognizes that non-direct-user States, Territories and Tribes may need to take steps
to adjust their own information systems to include all RIDE and then map to the
appropriate ICIS-NPDES XML schema so that data from their data systems will transfer
to ICIS-NPDES; such adjustments and mapping also should be addressed in transition
plans. EPA will rely on ICIS-NPDES for direct user States, Tribes and Regions and will
continue to rely on PCS information for non-direct-user States, Territories and Tribes
until they have migrated to ICIS-NPDES. PCS will be shut down once all States,
Territories and Tribes have been migrated to ICIS-NPDES.
NPDES-authorized States, Territories or Tribes have the flexibility within the
transition plan to identify a specific prioritization scheme for RIDE data entry or transfer
by specific dates. Although NPDES-authorized States, Territories or Tribes have
flexibility in the specifics of the transition plan, there are several national data targets
which should also be incorporated into the transition plan. These national targets, set
forth in Appendix 4, are intended to provide national consistency so that EPA can begin
to use ICIS-NPDES for national analysis for certain data sets.
5 Significant non-compliance (SNC) for SSSs and which informal enforcement actions will address such
SNC will be defined in the wet weather SNC guidance, currently under development by EPA.
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EPA has set national data targets based on permit type, program area and data
family. These national targets are based on an approach similar to that developed by the
Matrix Priority Workgroup, a subgroup of the Expanded Steering Committee, in June to
August 2006. These national target dates apply to all States, Territories, Tribes and
Regions, whether direct, hybrid or non-direct (batch) users of ICIS-NPDES, with the
provision that the dates may be extended as necessary up to four months after a State,
Territory, Tribe or Region migrates to ICIS-NPDES.
1. Ensure ICIS-NPDES data entry or transfer of those RIDE for which WENDB
equivalents existed in PCS
Existing WENDB elements are expected to be up-to-date when the permitting
authority begins RIDE data entry or transfer into ICIS-NPDES. States, Territories,
Tribes and Regions scheduled to migrate to ICIS-NPDES are encouraged to ensure that
all WENDB data is complete and accurate in PCS before data migration occurs.
Therefore, data entry or transfer into ICIS-NPDES for those RIDE for which WENDB
equivalents existed in PCS is expected to be available in ICIS-NPDES very early in the
transition period.
2. Entry of Non-DMR Compliance Monitoring, Violations and Enforcement as They
Occur
With the exception of certain stormwater construction sites as discussed in
Section E.8., data associated with non-DMR compliance monitoring (e.g., inspections),
single event violations, enforcement actions, penalties, and compliance schedules are to
be entered or otherwise made available into ICIS-NPDES as those events occur, and in
accordance with the Data Entry Protocols (described in Section E. 1.). Appropriate
linkages should be made within ICIS-NPDES, as described in Section E.5. If there is
compliance monitoring or enforcement activity at a facility without corresponding
Facility or Permit Data in ICIS-NPDES, then that Facility and/or Permit information
should be entered into ICIS-NPDES in order for compliance and enforcement events to
be properly entered into the system. As indicated in Appendix 4, enforcement actions,
inspections and violations are expected to be entered or transferred into ICIS-NPDES
prospectively after August 1, 2007, or within four months after migration to
ICIS-NPDES.
3. Phase-In of Limits and DMRs for Non-Majors
States, Territories, Tribes and EPA Regions may "phase-in" the data entry of
DMRs (and associated limits and limit sets) for non-majors. Under this phase-in, the data
entry or transmission of DMRs (also limits and limit sets) to ICIS-NPDES for non-majors
should be prioritized to focus initially on those non-majors located in priority watersheds
(impaired watersheds). Appendix 4 describes the national targets for DMR entry and
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availability in ICIS-NPDES for non-majors. These national data targets for DMR data
entry and transfer for non-major facilities are based on the concept that the permitting
authority may prioritize certain non-major facilities for DMR data entry, with DMR
RIDE for the other non-majors awaiting the availability of NetDMR. For the first few
years of implementation of this policy statement, EPA Headquarters will annually assist
each State, Tribe and Region by providing a list of non-major facilities located in priority
watersheds; this list could then be used for determining priorities for DMR (as well as
other RIDE) data entry into ICIS-NPDES.
4. Permit Data Not Yet Collected
If there is permit RIDE data that a State or Tribe currently does not collect or have
in its existing permit or permit application, availability of these particular data elements
in ICIS-NPDES may be delayed until reissuance of the permit. For example, if a
particular permit does not yet require the metadata associated with latitude and longitude
for pipe locations, those particular RIDE for that permittee may be delayed until
reissuance of the permit. All individual non-storm water NPDES permits are issued on a
five-year cycle; therefore, all permit RIDE should be complete within five years of
issuance of this Policy Statement.
G. Development and Implementation of Transition Plans
Each NPDES-authorized State, Territory, Tribe or EPA Region should develop a
transition plan which describes how and when RIDE data entry or transfer to
ICIS-NPDES will occur (note: data transfer is not available to EPA Regions other than in
the data migration from PCS to ICIS-NPDES). This transition plan should include an
implementation schedule designed to result in RIDE data entry or transfer into
ICIS-NPDES by the end of the transition period. The transition period applies primarily
to those RIDE without WENDB equivalents in PCS.
The approach taken to ensure such data entry or transfer into ICIS-NPDES may
vary to some degree by State, Territory, Tribe or Region depending on the current status
and projected availability of the data and resources. States, Territories, Tribes and
Regions are encouraged to work with the existing RIDE Data Entry Estimate Model
when developing their ICIS-NPDES transition plan to quantify and assess the resource
implications for data entry of specific data types or program areas.
The national ICIS-NPDES data targets are described in Appendix 4. A template
of a transition plan is included as Appendix 5.
The schedule for submission of such recommended transition plans will vary
based upon the type of ICIS-NPDES user (i.e., direct users, hybrid users and non-direct
users) (see Appendix 4). Hybrid and non-direct (batch) users have been given four
additional months to understand the ICIS-NPDES XML schemas as part of the process of
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developing their transition plans. The transition plan and milestone schedule for
NPDES-authorized States and Tribes will be reviewed and approved by EPA Regions at
the Division Director level (Enforcement and Water) within three months of submission
of that plan by the State or Tribe to EPA. Similarly, transition plans and milestone
schedules for non-authorized States, Territories and Tribes will be developed by EPA
Regions, with review and approval by EPA Headquarters within three months of
Regional submission. These activities are included in the ICIS-NPDES roles and
responsibilities table in Appendix 6.
EPA Regions should seek to incorporate the activities and schedule in the
approved transition plan into subsequent State-EPA or Tribe-EPA management
agreements, performance partnership grants (PPGs) or performance partnership
agreements (PPAs), when these agreements are due for renewal, throughout the transition
period. At the end of the transition period, when States and Tribes have fully
implemented RIDE entry, the State-EPA or Tribe-EPA management agreement, PPG or
PPA should be modified, when these agreements are due for renewal, to reflect the need
for continued timely, accurate and complete entry and availability of RIDE data.
H. Additional Operational Activities
To ensure a smooth and effective operation of ICIS-NPDES, permitting
authorities should undertake a variety of additional activities, including those listed
below:
1. Participate in ICIS-NPDES Governance: A governance structure with
Headquarters, Regional, and State representatives will be formed for making
decisions regarding ICIS Release 2.0 and subsequent releases. The governance
structure will institute a standard communication and decision-making process for
system enhancements and system issues.
2. Establish and Maintain Roles and Responsibilities: Defining and maintaining
clear roles, responsibilities and activities is essential to managing a decentralized
national data base such as ICIS-NPDES. Appendix 6 identifies these roles and
responsibilities for States, Territories, Tribes, EPA Regions, and for various
offices at EPA Headquarters.
3. Monitor Data Quality: As the data is migrated to the new system and as users
become familiar with ICIS-NPDES, permitting authorities should pay particular
attention to reviewing data reports and results to ensure that the data is entered
correctly and reporting is accurate and timely. As ICIS-NPDES problems arise,
they should be reported to user support; user support, in turn, will elevate
problems to the governance structure as appropriate.
As described earlier in this document, timely, accurate, complete and consistent
reporting is the foundation for effective program management and reliable public
access to data; therefore, data quality will remain an area of focus for ICIS-
ICIS-NPDES Policy Statement 13 April 30,2007 draft
-------
NPDES implementation. As States and Tribes move beyond transitioning into
ICIS-NPDES and the system becomes the established national NPDES data base
of record, careful attention should be paid by all parties to data quality, with
procedures and checklists in place to ensure that RIDE data is entered within set
timelines and is entered completely and accurately.
I. Policy Revision and Relationship to Other Policies
The NPDES program will continue to evolve. States and EPA will need to work
together to ensure that program guidance reflects program and policy changes. As new
guidance documents are developed or as existing guidance is modified, close
coordination between these documents and ICIS-NPDES will be needed to determine
whether and how ICIS-NPDES can support these changes. For example, EPA is
currently working with States on finalizing various guidance documents and policies that
may be useful to the NPDES-authorized agencies; such guidance documents and policies
include the wet weather SNC guidance document, the Compliance Monitoring Strategy,
the ICIS-NPDES Data Element Dictionary, and the Single Event Violation Data Entry
Guide. Changes needed to ICIS-NPDES to accommodate new regulations, guidance
documents, or policy will be directed to the established ICIS-NPDES governance
structure.
EPA expects to review on a periodic basis (of approximately five years) how well
this ICIS-NPDES Policy Statement is meeting the business needs of the NPDES
program. EPA anticipates that the first such review will occur two to three years after
issuance of this Policy Statement to assess the success of the transition plans and the
experience of working with the batch transfer process.
ICIS-NPDES Policy Statement 14 April 30,2007 draft
-------
APPENDIX 1:
RIDE by Data Area and Program Area
Core Data Requirements
Facility
Permitting
Compliance Monitoring
Enforcement
Total
# of Data
Elements
25
82
33
20
160
(incl. 22 conditional)
Additional 125 Special Regulatory Elements
NOTE:
123 RIDE
elements are
system -
required
Biosolids
17
CAFOs
49
(incl. 7 conditional)
CSO/SSOs
19
(incl. 12 conditional)
Pretreatment
33
(incl. 2 conditional)
Storm Water
7
Total RIDE Elements = 285 (including 43 conditional)
April 30, 2007 DRAFT
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
1. This column provides the PCS acronyms that correspond to each RIDE element. If blank, there is no known equivalent. Also, the PCS acronyms represent WENDB elements required in PCS, unless otherwise noted.
2. From the ICIS-NPDES Detailed Design Document (page 4-2): "Data elements are marked as system required when entry of the data element is required by ICIS-NPDES in order for a user to add a particular record into the system... If [system-Jrequired data
elements are not entered, ICIS-NPDES will reject the transaction."
3. From the ICIS 2.0 Users Guide (Permits section): "Unpermitted facilities are records established in ICIS to allow for tracking of activities (e.g., inspections and enforcement actions) that are associated with facilities that do not have [NPDES] permits. They
may not contain narrative conditions, schedules, or limits." Data entry requirements do not apply to those portions of a State program that are "broader in scope" than the approved NPDES program (under 33 U.S.C. ง 1342(b)). Except for SIUs innon-
preatreatment cities, the facility, compliance monitoring, and enforcement data for unpermitted facilities is only RIDE if there has been a formal enforcement action, an administrative penalty order or an informal enforcement action that addressed SNC. For
SIUs in non-pretreatment cities, PJDE is expected. Examples of unpermitted facilities include SSS satellite systems and AFOs that, after inspection, are determined to be CAFOs requiring a NPDES permit.
Note: Highlighted rows indicate RIDE that are conditionally-required and only need to be entered under certain circumstances, as described in the " Sytem-Required" column and the "Comment" column. Some of these fields are only required based on the
presence/ absence of another RIDE; others only need to be entered rarely.
Area
Sub-Area
Data Element Name
PCS equivalent
(if available)
RIDE Data Element Description
System
Required
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Master
General
Permits
General
Permit
Covered
Facility
Comment
FACILITY DATA ELEMENTS
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Facility Type of
Ownership
Facility Site Name
Address
City
State
Zip Code
Tribal Land
TYPO
RNAM
RST1
RCTY
RSTT
RZIP
HQ01
The code/ description identifying the type of facility (e.g.,
State Government, Municipal or Water Distric, Federal
Facility). This data element is used by the system to
populate the Permit Facility Type data element (i.e.,
POTW, Non-POTW, Federal).
The name of the facility.
The address of the physical facility location.
The name of the city, town, village, or other locality, when
identifiable, within whose boundaries (the maj ority of) the
facility site is located. This is not always the same as the
city used for LISPS mail delivery.
The LISPS abbreviation that represents the state or state
equivalent for the US and Canada.
The combination of the 5-digit Zone Improvement Plan
(ZIP) code and the 4-digit extension code (if available) that
represents the geographic segment that is a sub unit of the
ZIP Code assigned by the U.S. Postal Service to a
geographic location.
The Bureau of Indian Affairs code for every unit of land
within Indian Country.
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
2a-1
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APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Facility
Sub-Area
Lat/Long
Lai/Long
Lat/Long
Lat/Long
Lat/Long
Lat/Long
Lat/Long
Non-Gov
Contacts
Non-Gov
Contacts
Non-Gov
Contacts
Non-Gov
Contacts
Non-Gov
Contacts
Non-Gov
Address
Data Element Name
Longitude
Latitude
Facility Source Map
Scale Number
Horizontal Accuracy
VIeasure
Horizontal Collection
Method
Horizontal Reference
Datum
Reference Point
Affiliation Type
First Name
Last Name
Individual Title
Organization
Street Address
PCS equivalent
(if available)1
FLON
FLAT
FLLS
FLLC
FLLM
FLLT
FLLD
MNAM,ONAM
MST1,OST1
RIDE Data Element Description
The measure of the angular distance on a meridian east or
west of the prime meridian for a Facility Interest. Entered
in either Decimal Degrees or in Degrees Minutes Seconds;
stored in decimal degrees.
The measure of the angular distance on a meridian north or
south of the equator for a Facility Interest. Entered in
either Decimal Degrees or in Degrees Minutes Seconds;
stored in decimal degrees.
The number that represents the proportional distance on the
ground for one unit of measure on the map or photo.
The measure of the accuracy (in meters) of the latitude and
.ongitude coordinates.
The text that describes the method used to determine the
.atitude and longitude coordinates for a point on the earth.
The code/ description that represents the reference datum
used in determining latitude and longitude coordinates.
The code/ description for the place for which geographic
coordinates were established.
The way that the contact is affiliated with the Facility (e.g.,
Owner)
The given name of an individual.
The surname of an individual.
The title held by a person in an organization.
The legal, formal name of an organization that is affiliated
with the facility site.
The address that describes the physical location of a
Duilding or event, including urban-style street address or
rural address.
System
Required
No
No
No
No
No
No
No
No
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
except for Storm Water -
construction permits
except for Storm Water -
construction permits
except for Storm Water -
construction permits
except for Storm Water -
construction permits
except for Storm Water -
construction permits
except for Storm Water -
construction permits
except for Storm Water -
construction permits
Only for Affiliation Type
"Owner", "Main Contact", and
"Operator"
Only for Affiliation Type
"Owner", "Main Contact", and
"Operator"
Only for Affiliation Type
"Owner", "Main Contact", and
"Operator"
Only for Affiliation Type
"Owner", "Main Contact", and
"Operator"
Only for Affiliation Type
"Owner", "Main Contact", and
"Operator"
Only for Affiliation Type
"Owner", "Mailing", and
"Integrator" (only for CAFOs)
2a-2
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APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Facility
Facility
Facility
Facility
Facility
Sub-Area
Non-Gov
Address
Non-Gov
Address
Non-Gov
Address
Non-Gov
Address
Non-Gov
Address
Data Element Name
Affiliation Type
Organization Formal
STame
City
State
Zip Code
PCS equivalent
(if available)1
MNAM,ONAlv:
MCTY, OCTY
MSTT, OSTT
MZIP, OZIP
RIDE Data Element Description
The way that the contact or address is affiliated with the
Facility (e.g., Owner)
The legal, formal name of an organization that is affiliated
with the facility site.
The name of the city in which the address exists.
The U.S. Postal Service abbreviation that represents the
state or state equivalent for the U.S.
The combination of the 5-digit Zone Improvement Plan
(ZIP) code and the 4-digit extension code (if available) that
represents the geographic segment that is a sub unit of the
ZIP Code assigned by the U.S. Postal Service to a
geographic location.
System
Required
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Comment
Only for Affiliation Type
'Owner", "Mailing", and
' Integrator" (only for CAFOs)
Only for Affiliation Type
"Owner", "Mailing", and
"Integrator" (only for CAFOs)
Only for Affiliation Type
"Owner", "Mailing", and
"Integrator" (only for CAFOs)
Only for Affiliation Type
"Owner", "Mailing", and
"Integrator" (only for CAFOs)
Only for Affiliation Type
"Owner", "Mailing", and
"Integrator" (only for CAFOs)
PERMIT DATA ELEMENTS
Permit
Permit
Permit
Permit
Permit
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
NPDESID
Master General Permit
Number
Permit Type
Issue Date
Effective Date
NPID
NPID
PTYP
PTEV, PTAC
(PERD)
PTEV, PTAC
(PEFD)
This is the NPDES permit number.
The unique identifier of the master general permit which is
linked to a General Permit Covered Facility.
The unique code/ description identifying the type of permit
This is the date the permit was issued.
This is the date on which the permit is effective.
Yes
Yes, when adding
a General Permit
Covered Facility
permit.
Yes
Not for new
permits, but for
compliance
tracking or
reissuance
Not for new
permits, but for
compliance
tracking or
reissuance
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Only when adding a General
Permit Covered Facility
permit.
2a-3
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Sub-Area
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Data Element Name
Expiration Date
Termination Date
Vlaj or/Minor Rating
Code
Total App. Design Flow
Total App. Actual Avg.
Flow
Complete
Application/NOI
Received Date
Application/NOI
Received Date
Permit Status
General Permit
[ndustrial Category
[ssuing Organization
Type
DMR Non-Receipt
RNC
Applicable Effluent
Limit Guideline
PCS equivalent
(if available)1
PTEV, PTAC
(PERE)
IADT
MRAT
FLOW
FLOW
PTEV (P2099)
(not WENDB),
PTAC
PTEV, PTAC
(APRD)
GPCT
EPST
CFRC
RIDE Data Element Description
This is the date the permit will expire.
This is the date the permit was terminated.
This is the numeric total of ranking points assigned to non-
POTW facilities and used to delineate them as a major or
minor facility. The numeric value entered for this data
element comes from the total score assigned to the facility
on the NPDES Permit Ranking Work Sheet.
This is the flow that a permitted facility was designed to
accommodate, in MGD.
This is the actual flow that a permitted facility
accomodated based on the application, in MGD.
This is the date on which the complete application for a
MPDES permit was received.
This is the date on which the application for a NPDES
aermit was received.
This is a code/ description that indicates whether the permit
is Effective, Expired, Administratively Continued, Pending
Mot Needed, Retired, or Terminated.
This code/ description that identifies the industrial category
of a general permit.
This is the type of organization issuing or granting a permit
Turns Non-Receipt tracking on/offfbr Minors. Always on
for Majors. Defaulted initially to On.
Turns RNC tracking on/off for Minors. Always on for
Vlajors. Defaulted initially to On.
The effluent guideline that applies to the permit.
System
Required
Not for new
permits, but for
compliance
tracking or
reissuance
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
Yes
Yes
Yes
Yes
Yes
Yes
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
The flow that a permitted facility
actually had at the time of
application.
Either complete date or received
data must be entered because this
element is tied to "Permit status".
Either complete date or received
data must be entered because this
element is tied to "Permit status".
Effective, Expired,
Administratively Continued,
Pending, Retired are system-
generated based on Permit dates.
Not Needed and Terminated are
manually entered.
System -generated to "yes" for all
aermits. Change to "no" for
minors must be manually entered
System -generated to "yes" for all
aermits. Change to "no" for
minors must be manually entered
2a-4
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APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Sub-Area
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Permittee
Permittee
Permittee
Permittee
Data Element Name
Compliance Tracking
Status
Compliance Tracking
Status Start Date
RNC Status Quarter
RNC Status Year
RNC Status (Manual)
SIC Codes
Associated NPDES
Permit
NAICS Codes
Street Address
Organization Formal
Maine
Zip Code
City
PCS equivalent
(if available)1
IACC
IADT
CYMS, PYMS
GYMS, PYMS
CYMS, PYMS
SIC2
SLID
RST1
NAM1
RZIP
RCTY
RIDE Data Element Description
This is a code/ description that indicates whether the permit
is currently on or off for compliance tracking purposes.
[nitially system-generated to match effective date.
This is the date on which the permit's on or off period for
compliance tracking status began. Initially system-
generated to match effective date.
The quarter of the Permit RNC status.
The year of the Permit RNC status.
The status of reportable noncompliance as it was entered
by the user before the official QNCR for the RNC quarter
for the permit.
The four digit Standard Industrial Classification (SIC)
code/ description that represents the economic activity of a
company.
This is the NPDES number of the associated permits.
The six digit code/ description that represents a subdivision
of an industry that accomodates user needs in the US .
The address that describes the physical location of the
aermittee.
The legal, formal name of an organization that is affiliated
with the facility site.
The combination of the 5-digit Zone Improvement Plan
(ZIP) code and the 4-digit extension code (if available) that
represents the geographic segment that is a sub unit of the
ZIP Code assigned by the U.S. Postal Service to a
geographic location.
The name of the city, town, or village where the mail is
delivered.
System
Required
Yes
Yes
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
Yes
Yes
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
System -generated for web users;
RIDE for batch users.
System -generated for web users;
RIDE for batch users .
2a-5
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APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Sub-Area
Permittee
Bios oil ds
Biosolids
Bios oil ds
Biosolids
Biosolids
Biosolids
Biosolids
Biosolids
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
Data Element Name
State
Annual Dry Sludge
Production
Amount EQ Product
Distribute and
Marketed
Amount Land Applied
Amount Incinerated
Amount Codisposed in
an MSW Landfill
Amount Surface
Disposal
Amount Managed
Other Methods
Biosolids End Use
Disposal Type
Designation Reason
CAFO Designation
Date
Solid Manure or Litter
Generated
Solid Manure or Litter
Transferred
Liquid Manure or
Wastewater Generated
Liquid Manure or
Wastewater Transferred
PCS equivalent
(if available)1
RSTT
SLPV
SLDG
RIDE Data Element Description
The U.S. Postal Service abbreviation that represents the
state or state equivalent for the U.S.
The amount of sludge a facility produces in DMT/year on a
dry weight basis .
The amount (dry metric tons) of EQ product distributed.
The amount (dry metric tons) of biosolids land applied.
The amount (dry metric tons) of biosolids incinerated.
The amount of dry metric tons co-disposed in a MSW
landfill.
The amount (dry metric tons) of biosolids used for surface
disposal.
The amount (dry metric tons) of biosolids managed using
methods not previously described.
This is the code identifying the type of end use disposal.
If the facility was designated, indicate the reason the
facility was designated, such as the amount of waste
reaching waters, location, slope, rainfall, etc.
[f the facility received a permit as a result of being
designated, indicate the date on which the facility is
designated as a CAFO.
The total amount of manure in tons generated annually by
he facility.
The number of tons of manure or litter produced by the
CAFO that will be transferred to other persons.
The total amount of manure in gallons generated annually
ay the facility.
The total amount of manure in gallons produced by the
CAFO that will be transferred to other persons.
System
Required
Yes
No
No
No
No
No
No
No
No
Yes, if "yes" is
entered for "Is the
Animal Facility a
CAFO?" and
"small" is entered
for CAFO
classification
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with Biosolids permit component
with Biosolids permit component
with Biosolids permit component
and permitted feature type of
.and application site
with Biosolids permit component
and permitted feature type of
incinerator
with Biosolids permit component
and permitted feature type of co-
disposal site
with Biosolids permit component
and permitted feature type of
surface disposal site
with Biosolids permit component
with Biosolids permit component
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
2a-6
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APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Sub-Area
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
Storm Water
Storm Water -
Construction
Storm Water -
Construction
Storm Water -
Industrial
Data Element Name
NMP Developed Date
CAFO Classification
Animal: Type
Animal: Other
Total Number
Containment: Type
Containment: Total
Capacity
Containment: Other
Storage: Type
Storage: Other
Days of Storage
Storage Total Capacity
Vleasure
State Water Body Name
NOT Terminate Date
Entire Project Size
NOT Terminate Date
PCS equivalent
(if available)1
RWAT?
RIDE Data Element Description
The date that an NMP was developed by the facility.
The unique code/ description that identifies the how the
facility was classified for a "Concentrated Animal Feeding
Operation?" Options are Large, Medium and Small
(Designation).
The unique code/ description that identifies the operation's
applicable animal sector(s).
The free-form text field to describe the operation's
applicable animal sector if Other is selected for Animal
Type Code.
The total number of each type of livestock at the facility.
The unique code/ description for the type of containment
used by the operation.
The total capacity, in gallons, of the containment structure.
The free- form text field to describe the type of containment
if Other is selected for Containment Type Code.
The unique code/ description that describes the type of
storage used by the CAFO.
The free- form text field to describe the type of storage used
ay the operation if the Other code is selected for storage
tvpe code attribute.
This is how many days of storage there were for each
storage type selected.
This is the total capacity, in tons or gallons, of the storage
structure.
This identifies the name(s) of the receiving water into
which the storm water flows directly.
This is the date on which the facility"s coverage was
terminated.
This code describes the plan size of the project (<1 acre, 1-
5 acres, or >5 acres).
This is the date on which the coverage was terminated.
System
Required
No
No
Yes
No
No
Yes
No
No
Yes
No
No
No
No
One data element
must be entered
in this section to
save the record
At least 1 element
is required to save
this component
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component.
Required onlyif "other" is
selected under "animal type".
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component.
Required onlyif "other" is
selected under "containment
tvpe".
with CAFO Permit Component.
Required onlyif "other" is
selected under "storage type".
with CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with Storm Water Permit
Component
with a Storm Water -
Construction Permit Component
with a Storm Water -
Construction Permit Component
with Storm Water - non-
construction components
2a-7
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APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Permit
Sub-Area
Storm Water -
Industrial
Storm Water -
MS4
Storm Water -
MS4
CSO
CSO
CSO
CSO
Pretreatment
Pretreatment
Pretreatment
POTW
Data Element Name
STo Exposure
Authorized Date
MS4 Permit Class
Receiving MS4 Name
CSS Population Served
Percent of Collection
System Combined
Name of CSS Satellite
Collection System
Permit ID of CSS
Satellite Collection
System
Pretreatment Program
Required Indicator
Pretreatment Program
Approved Date
Control Authority
NPDESID
SSCS Population
Served
PCS equivalent
(if available)1
PRET
CAID
RIDE Data Element Description
This is the date on which the No Exposure Waiver was
authorized.
This is the code/ description that identifies the regulatory
Dasis for MS4 permit (sm all/m edium/large)
This is the name of the receiving MS4(s).
This is the population served by the combined sewer
system (individuals or households).
This is the percentage of the total collection system that is
combined.
This is the name of each satellite collection system
providing flow to the permittee.
This is the permit ID of each satellite collection system
providing flow to the permittee.
The code/ description indicating if the permitted
municipality is required to develop a pretreatment program.
The date the pretreatment program is approved.
The permit ID of the POTW's or lU's control authority.
This is the population served by the sanitary sewer
collection system (individuals or households). This data
element applies to all POTWs.
System
Required
No
Yes
No
Yes
Yes
No
No
Yes
Yes, if
Pretreatment
Program
Required
Indicator is
"Approved" .
Yes, if
PRetreatment
Program
Required
Indicator is
"Covered".
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with Storm Water - non-
construction components
with Stom Water-MS4 Permit
Component
with Stom Water-MS4 Permit
Component
with CSO Permit Component
with CSO Permit Component
with CSO Permit Component
with CSO Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW Permit Component
2a-8
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permit
Sub-Area
POTW
Data Element Name
Length of SSCS
PCS equivalent
(if available)1
RIDE Data Element Description
This is the number of miles of pipe in the sanitary sewer
collection system.
System
Required
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Comment
with POTW Permit Component
Narrative Conditions/ Permit Schedules
Narr. Cond/Permit
Schedule
Narr. Cond/Permit
Schedule
Narr. Cond/Permit
Schedule
Narr. Cond/Permit
Schedule
Narr. Cond/Permit
Schedule
Narr. Cond/Permit
Schedule
Narr.Cond/
Schedule
Narr.Cond/
Schedule
Event
Event
Event
Event
Description
Narrative Condition
Number
Schedule Date
Actual Date
Report Received Date
Event
CSCH, VCSN,
EVSN
DISC, CVDT
DTAC
DTRC
EVNT, CVEV,
EVEV
The unique code/ description that identifies the type of
narrative condition.
This identifies a narrative condition and its elements
uniquely for a permit.
The date on which a schedule event is due to be completed
and against which compliance will be measured.
The date on which the permittee achieved the schedule
event
The date on which the regulatory authority receives a repor
(generally a letter) from the permittee indicating that a
Schedule Event was completed (e.g., Start Construction) or
the required report was enclosed.
The code/ description indicating the particular event with
which the permittee is scheduled to comply.
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
System -generated for web users;
RIDE for batch users.
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Lat/Long
Lat/Long
Application Design
Flow (MGD)
Application Actual
Average Flow (MGD)
Permitted Feature ID
Master General
Category ID
Type
Latitude
Longitude
DSCH, PLDS
DSCH
OUTT
PLAT
PLON
The flow that a permitted feature was designed to
accommodate, in MGD.
The flow that a permitted feature actually had at the time of
application, in MGD.
The identifier assigned for each location at which
conditions are being applied.
The identifier assigned for each location at which
conditions are being applied.
The code/ description indicating the type of permitted
feature (e.g. External Outfall, Sum).
The measure of the angular distance on a meridian north or
south of the equator for a Permitted Feature; stored in
decimal degrees.
The measure of the angular distance on a meridian east or
west of the prime meridian for a Permitted Feature; stored
in decimal degrees.
No
No
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
same as below
same as above
except for permits with Storm
Water - construction permitted
features
except for permits with Storm
Water - construction permitted
features
2a-9
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Permitted Feature
Sub-Area
Lat/Long
Lat/Long
Lat/Long
Lat/Long
Lat/Long
Data Element Name
Horizontal Accuracy
Measure
Reference Point
Source Map Scale
Slumber
Horizontal Collection
Method
Horizontal Reference
Datum
PCS equivalent
(if available)1
PLLC
PLLD
PLLS
PLLM
PLLT
RIDE Data Element Description
The measure of the accuracy (in meters) of the latitude and
.ongitude coordinates.
The code/ description for the place for which geographic
coordinates were established.
The number that represents the proportional distance on the
ground for one unit of measure on the map or photo.
The code/ description that represents the method used to
determine the latitude and longitude coordinates for a point
on the earth.
The code/ description that represents the reference datum
used in determining latitude and longitude coordinates.
System
Required
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Comment
except for permits with Storm
Water - construction permitted
features
except for permits with Storm
Water - construction permitted
features
except for permits with Storm
Water - construction permitted
features
except for permits with Storm
Water - construction permitted
features
except for permits with Storm
Water - construction permitted
features
Limit Set
Limit Set
Limit Set
Limit Set
Limit Set
Limit Set
Limit Set
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Limit Set Designator
Type
Default Months
Limit Set Applies
Initial Monitoring Date
Initial DMR Due Date
Number of Report Units
DRID, PLRD
ALLP
STRP
STSS, STSU
NRPU
The alphanumeric field that is used to designate a particular
grouping of parameters within a limit set.
The unique code/ description identifying the type of limit
set (i.e. Scheduled, Unscheduled).
The default months that the limit set applies. Defaults to al
2 months.
The date on which monitoring starts for the first monitoring
period for the limit set; this date will be blank for
Unscheduled Limit Sets.
The date that the first DMR for the limit set is due to the
regulatory authority; this date will be blank for
Unscheduled Limit Sets.
The number of months in the monitoring periods for the
DMRs for the limit set (e.g., monthly = 1, semi-annually =
6, quarterly = 3).
Yes
Yes
Yes
Yes, except for
unscheduled limit
sets
Yes, except for
unscheduled limit
sets
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
System -generated for web users;
RIDE for batch users.
2a-10
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Limit Set
Limit Set
Limit Set
Sub-Area
Basic Info
Basic Info
Basic Info
Data Element Name
Mumber of Submission
Units
Compliance Tracking
Status Start Date
Status
PCS equivalent
(if available)1
NSUS, NSUN
PIDT
PIAC
RIDE Data Element Description
The attribute stores the number of months for submitting
the DMRs for the limit set (e.g., monthly = 1, semi-
annually = 6, quarterly = 3); this data element will be blank
for Unscheduled Limit Sets.
The date that the Limit Set Status started.
The status of the Limit Set (i.e., Active or Inactive); Limit
Sets will not have violations generated when a Limit Set is
Inactive unless an Enforcement Action Limit is present
System
Required
Yes, except for
unscheduled limit
sets
Yes
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Comment
Defaults to active
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Monitoring Location
Seas on Number
Start Date
End Date
Change of Limit Status
Indicator
Stay Type
Stay Start Date
Stay End Date
MLOC
SEAN, ESEA
ELSD, FLSD,
ILSD, MLSD
ELED, FLED,
ILED, MLED
COLS
CONP
PTEV (P7099),
PTAC
The code/ description of the monitoring location at which
sampling should occur for a limit parameter.
Indicates the season of a limit and is used to enter different
seasonal limits for the same parameter within a single limit
start and end date.
The date on which a limit starts being in effect for a
particular parameter in a limit set.
The date on which a limit stops being in effect for a
particular parameter in a limit set.
The code/ description that describes circumstances
affecting limits, such as formal enforcement actions or
permit modifications.
The unique identifier of the type of stay applied to a limit
(e.g., X, Y, Z), which indicates whether the limits do not
appear on the DMR at all, are treated as monitor only, or
have a stay value in effect during the period of the stay.
The date on which a limit stay begins.
The date on which a limit stay is lifted.
Yes
Yes
Yes
Yes
No
Yes
Yes, if Stay Type
is entered
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
System -generated for batch
users; RIDE for web users.
2a-11
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Sub-Area
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Data Element Name
Reason for Stay
Stay Limit Value
Limit Type
Enforcement Action ID
Final Order ID
Eligible for Burden
Reduction
Modification Effective
Date
Modification Type
Parameter
Months
Value Type
Quantity Units /
Concentration Units
PCS equivalent
(if available)1
MCMX,
MCAV,
MCMN,
MQMX, MQAV
OUTT
PLFN
PTEV, PTAC
(PMDD)
PRAM
ALLS (not
WENDB)
LCMX, LCMN,
LCAV, LQMX,
LQAV
LCUC, LQUC
RIDE Data Element Description
The text that represents the reason a stay was applied to a
imit.
The numeric limit value imposed during the period of the
stay for the limit; if entered, during the stay period, the
system will use this limit value for calculating compliance
rather than the actual limit value.
The code that indicates whether a limit is an enforceable or
an alert limit (e.g., action level, benchmark) that does not
receive effluent violations.
The unique identifier for the Enforcement Action that
imposed the Enforcement Action limit; this data element
lelps tie the limit record to the Final Order record in the
database.
The unique identifier for the Final Order that imposed the
Enforcement Action limit; this data element ties the limit
record to the Final Order record in the database.
The indication of whether a limit parameter is eligible for
monitoring burden reduction.
The effective date of the permit modification that created
this limit.
The type of permit modification that created this limit (e.g.
major, minor, permit authorized change).
The unique code/ description identifying the parameter
aeing limited and/or monitored.
The months that the limit applies . Defaults to limit set
months.
The indication of the limit value type (e.g., Quantify 1,
Concentration 2).
The code/ description representing the unit of measure
applicable to quantify or concentration limits as entered by
the user.
System
Required
Yes, if Stay Type
is entered
Yes, when Stay
Type is "Z".
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No, except to
save limit value.
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
Yes
Yes
Yes
Yes
Yes
Yes
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
This defaults to an enforceable
imit. The user can optionally
change it to an alert limit.
Only RIDE if the limit is an EA
Limit.
Only RIDE if the limit is an EA
Limit.
Defaults to "no".
System -generated for web users;
RIDE for batch users.
2a-12
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Limit
Limit
Limit
Limit
Sub-Area
Basic Info
Basic Info
Basic Info
Basic Info
Data Element Name
Statistical Base Code
Optional Monitoring
Flag
Qualifier
Value
PCS equivalent
(if available)1
LCXS, LCAS,
LCMS, LQXS,
LQAS
LCMX/LCMN/
LCAV/ LQMX/
LQAV
(OPMON)
LCMX, LCMN,
LCAV, LQMX,
LQAV
RIDE Data Element Description
The code/ description representing the unit of measure
applicable to the limit and DMR values entered by the user
(e.g., 30-day average, daily maximum) CHECK DATA
STANDARD.
The flag allowing users to indicate that monitoring is
optional but not required (i.e., effluent violation generation
will be suppressed for optional columns).
The unique code identifying the limit value operator (e.g.
<=,<,).
The actual limit value number from the Permit or
Enforcement Action Final Order.
System
Required
No, except to
save limit value.
Yes
Yes
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Master
General
Permits
Yes
Yes
Yes
Yes
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Comment
Defaults to "no".
It defaults to "=".
COMPLIANCE MONITORING DATA E
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Compliance Monitoring
Activity Actual End
Date
Compliance Monitoring
Activity Planned End
Date
State
Compliance Activity
Type
Compliance Monitoring
Type
Bio-Monitoring
Inspection Method
Compliance Monitoring
Category
Compliance Monitoring
Action Reason
DTIN, DTIA
SIDT (not
WENDB)
TYPI
TYPI
The actual date on which the Compliance Monitoring
Activity ended.
The planned date for the Compliance Monitoring Activity
to end.
The US Postal Service abbreviation that represents that
state or state equivalent for the U.S.
The unique code/ description that identifies a type of
compliance event or enforcement action.
The code/ description indicating the type of compliance
monitoring activity taken by a regulatory Agency.
The unique code that identifies the type of biomonitoring
inspection method. This data element supplements the
Compliance Monitoring Category and Compliance
Monitoring Type Inspection Type recorded for all
inspections.
The unique code/ description identifying the compliance
monitoring or inspection category code/ description.
The unique code that identifies the purpose of an activity.
Yes, if there is no
planned end date
Yes, if there is no
actual end date
Yes
Yes
Yes
Yes, if "bio-
monitoring" is
entered as
Compliance
Monitoring Type
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
RIDE if Planned End Date not
entered
RIDE if Actual End Date not
entered
States only - prepopulated based
on user profile
System -generated for batch
users; RIDE for web users.
System -generated for batch
users; RIDE for web users.
2a-13
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Sub-Area
Basic Info
Basic Info
Basic Info
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
Data Element Name
Was this a State,
Federal or Joint
(State/Federal)
[nspection?
Compliance Monitoring
Agency Type
Law Sections Violated
Designation Reason
Animal: Type
Animal: Other (Please
specify)
Animal: Total Number
Containment: Type
Containment: Total
Capacity
Containment: Other
CAFO Classification
CAFO Designation
Date
Solid Manure or Litter
Generated
PCS equivalent
(if available)1
INSP
INSP
TYPI
RIDE Data Element Description
The flag indicating if the inspection is a joint inspection of
federal and state.
Whether if s an EPA or State Inspection
The unique identifier for the Section(s) of law violated and
cited in the activity.
If the facility was designated, indicate the reason the
facility was designated, such as the amount of waste
reaching waters, location, slope, rainfall, etc.
The unique code/ description that identifies the operation"s
applicable animal sector(s).
The free-form text field to describe the CAFO's applicable
animal sector if Other is selected for Animal Type.
The total number of each type of livestock at the facility.
The unique code/ description for the type of containment
used by the operation.
The total capacity, in gallons, of the containment structure.
The free- form text field to describe the type of containment
if Other is selected for Containment Type.
The unique code/ description that identifies the how the
facility was classified for a "Concentrated Animal Feeding
Operation?" Options are Large, Medium and Small
(Designation).
The date on which the facility is designated as a
Concentrated Animal Feeding Operation (CAFO).
The total amount of manure in tons generated annually by
the facility.
System
Required
No
Yes
No
Yes, if "yes" is
entered for "Is the
Animal Facility a
CAFO?" and
"small" is entered
for CAFO
classification
No
No
No
No
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with CAFO Permit Component
with CAFO permit component
with CAFO Permit Component.
Required onlyif "other" is
selected under "animal type".
with CAFO permit component
with CAFO permit component
with CAFO permit component
with CAFO Permit Component.
Required onlyif "other" is
selected under "containment
type".
with CAFO permit component
with CAFO permit component
with CAFO permit component
2a-14
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Sub-Area
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CSO
CSO
CSO
Data Element Name
Solid Manure or Litter
Transferred
Liquid Manure or
Wastewater Generated
Liquid Manure or
Wastewater Transferred
NMP Developed Date
NMP Last Updated
Date
[s the Animal Facility
Type a CAFO?
Storage: Type
Storage: Other
Days of Storage
Storage Total Capacity
Measure
Permitted Feature
[dentifier
Location Street Address
Longitude
PCS equivalent
(if available)1
RIDE Data Element Description
The number of tons of manure or litter produced by the
CAFO that will be transferred to other persons.
The total amount of manure in gallons generated annually
yy the facility.
The number of gallons of manure or litter produced by the
CAFO that will be transferred to other persons.
The date that an NMP was developed by the facility.
The date that the NMP was last updated by the facility.
The flag to indicate if the facility is classified as a CAFO 01
not.
The unique code/ description that describes the type of
storage used by the operation.
The free- form text field to describe the type of storage used
ay the operation if the Other code is selected for storage
type code attribute.
The number of days of storage there were for each storage
type selected.
The total capacity, in tons or gallons, of the storage
structure.
The unique identifier for the permitted feature number
entered by the user for the CSO.
The street address location of the overflow.
The measure of the angular distance on a meridian east or
west of the prime. Entered in either Decimal Degrees or in
Degrees Minutes Seconds; stored in decimal degrees.
System
Required
No
No
No
No
No
No
No
No
No
No
Yes, if CSO
Overflow Location
Street Address or
^at/long info is not
entered
Yes, if Permitted
"eature Identifier or
^at/long info is not
entered
Yes, if CSO
Overflow Location
Street Address or
Permitted Feature
identifier is not
entered
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with CAFO permit component
with CAFO permit component
with CAFO permit component
with CAFO permit component
with CAFO permit component
with CAFO permit component
with CAFO permit component
with CAFO Permit Component.
Required onlyif "other" is
selected under "storage type".
with CAFO permit component
with CAFO permit component
with Law Section for CSO
with Law Section for CSO
with Law Section for CSO
2a-15
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Sub-Area
cso
cso
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
SSO
SSO
Data Element Name
Latitude
CSO Overflow Event
Date
SIUs
SIUs Without Control
Mechanism
SIUs Not Inspected
SIUs Not Sampled
SIUs in SNC with
Pretreatment Standards
SIUs in SNC with
Reporting
Requirements
CIUs
Pass-Through/
[nterference Indicator
Location Street Address
Longitude
PCS equivalent
(if available)1
SIUS
NOCM
NOIN
NINF
SNPS (not
WENDB),
PSNC
RSNC (not
WENDB),
PSNC
CIUS
PASS, INTF
(not WENDB)
RIDE Data Element Description
The measure of the angular distance on a meridian north or
south of the equator. Entered in either Decimal Degrees or
in Degrees Minutes Seconds; stored in decimal degrees.
The date of the actual CSO overflow event.
The total number of SIUs.
The number of SIUs for which a current control
mechanism is required but not yet issued or has expired, as
observed during the program audit or PCI.
The number of SIUs not inspected within the reporting
year, as observed during the program audit or PCI.
The number of SIUs not sampled within the reporting year,
as observed during the program audit or PCI.
The significant industrial users in SNC with pretreatment
standards within the reporting year, observed during the
program audit or PCI.
The significant industrial users in SNC with reporting
requirements within the reporting year, as observed during
the program audit or PCI.
The total number of CIUs.
The flag indicating if there have been any incidents of pass-
through or interference at the POTW within the reporting
year, as observed during the program audit or PCI.
The street address location of the overflow event.
The measure of the angular distance on a meridian east or
west of the prime. Entered in either Decimal Degrees or in
Degrees Minutes Seconds; stored in decimal degrees.
System
Required
Yes, if CSO
Overflow Location
Street Address or
Dermitted Feature
identifier is not
entered
Yes
Yes, if any
compliance
monitoring SIU
information is
entered.
No
No
No
No
No
No
No
Yes, if Lat/long info
is not entered
Yes, if Location
Street Address is not
entered
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Comment
with Law Section for CSO
with Law Section for CSO
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for "CWA
301/307 - Effluent Limitations
NPDES Toxic & Pretreatment
Effluent..."
with Law Section for SSO
with Law Section for SSO
2a-16
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Compliance
Monitoring Activity
Compliance
Monitoring Activity
Sub-Area
sso
sso
Data Element Name
Latitude
SSO Event Date
PCS equivalent
(if available)1
RIDE Data Element Description
The measure of the angular distance on a meridian north or
south of the equator. Entered in either Decimal Degrees or
in Degrees Minutes Seconds; stored in decimal degrees.
The date for which the SSO event is being reported.
System
Required
Yes, if Location
Street Address is not
entered
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Comment
with Law Section for SSO
with Law Section for SSO
DMR
DMR
DMR
DMR
DMR
DMR
DMR
DMR
DMR
DMR
DMR
DMR
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Permitted Feature
Limit Set
Parameter Code
Monitoring Location
Monitoring Period End
Date
NODI
Value
Concentration Units/
Quantity Units
Value Received Date
Value Type
Qualifier
VDSC, EVDS
VDRD, EVRD
VPRM.EVPR
VMLO.EVML
MVDT
NODI
MCMX,
MCAV,
MCMN,
MQMX, MQAV
RCUN, RUNT
(not WENDB)
DMRR (not
WENDB)
MCMX,
MCAV,
MCMN,
MQMX, MQAV
MCMX,
MCAV,
MCMN,
MQMX, MQAV
The identifier assigned for each location at which
conditions are being applied.
The unique identifier tying the DMR form to its Limit Set
record.
The unique code/ description identifying the parameter
reported on the DMR.
The code/ description of the monitoring location at which
the sampling occurred for a DMR parameter.
The date that the monitoring period for the values covered
by this DMR form ends.
The unique code/ description that indicates the reason that
"No Discharge" or "No Data" was reported in place of the
DMR value.
The DMR value number reported on the DMR form.
The code/ description representing the unit of measure
applicable to quantity or concentration limits and
measurements as entered by the user on the DMR form.
The date the DMR value was received by the regulatory
authority.
The unique code/ description identifying a DMR value type
(i.e. Quantity 1, Quantity 2, Concentration 1, Concentration
2, Concentration 3).
The unique code identiiying the DMR value operator (e.g.,
<, T, >, E, =). It defaults to "=".
Yes
Yes
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
System-generated for web users;
RIDE for batch users.
System -generated for web users;
RIDE for batch users .
System -generated for web users;
RIDE for batch users .
System -generated for web users;
RIDE for batch users.
System -generated for web users;
RIDE for batch users.
System -generated for web users;
RIDE for batch users .
2a-17
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
DMR
DMR
DMR
DMR
DMR
DMR
DMR
Sub-Area
Biosolids -
Incinerator
Biosolids -
Incinerator
Biosolids - Land
Application Site
Biosolids - Land
Application Site
Biosolids - Land
Application Site
Biosolids -
Surface Disposal
Biosolids -
Surface Disposal
Data Element Name
Compliance with
STational Emission
Standard for Beryllium
in 40 Code of Federal
Regulations (CFR) Part
61
Compliance with
STational Emission
Standard for Mercury in
40 CFR Part 61
Pollutant Table(s) Met
Does facility certify
pathogen reduction for
land application?
Does the Facility certify
Vector Attraction
Reduction for land
application?
Does facility certify
pathogen reduction for
surface disposal?
Does facility certify
vector attraction
reduction for surface
disposal?
PCS equivalent
(if available)1
RIDE Data Element Description
The flag indicating whether the facility is in compliance
with the National Emission Standard for Beryllium in 40
CFR Part 61.
The flag indicating whether the facility is in compliance
with the National Emission Standard for Mercury in 40
CFR Part 61.
The code/ description identifiying the pollutant table in the
^iosolids regulations (i.e. 1-4) that was met by the facility
for land application on this DMR.
The flag indicating if the facility certifies pathogen
reduction for surface disposal.
The flag indicating if the facility certifies Vector Attraction
Reduction (VAR) for surface disposal.
The flag indicating if the facility certifies pathogen
reduction for surface disposal.
The flag indicating if the facility certifies Vector Attraction
Reduction (VAR) for surface disposal.
System
Required
No
No
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with Biosolids permit component
and permitted feature type of
incineration
with Biosolids permit component
and permitted feature type of
incineration
with Biosolids permit component
and permitted feature type of
.and application
with Biosolids permit component
and permitted feature type of
.and application
with Biosolids permit component
and permitted feature type of
.and application
with Biosolids permit component
and permitted feature type of
surface disposal
with Biosolids permit component
and permitted feature type of
surface disposal
Violations
Violation
Violation
Basic Info
Basic Info
NPDESID
Violation Code
NPID
CVIO, MVIO,
SVCD
The activity ID of the permit to which the violation is
associated.
The code/ description identifying which type of Violation
has occurred (e.g., D80 = Required Monitoring DMR
Value Non- Receipt, E90 = Effluent Violation, C20 =
Schedule Event Achieved Late).
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
2a-18
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Violation
Violation
Violation
Violation
Violation
Violation
Violation
Sub-Area
Basic Info
Basic Info
Basic Info
RNC
RNC
RNC
RNC
Data Element Name
Single Event Violation
Date
Single Event Start Date
Single Event End Date
RNC Detection Code
RNC Detection Date
RNC Resolution Code
RNC Resolution Date
PCS equivalent
(if available)1
SVDT
SNCC, SNCE,
SNCS
SNDC, SNDE,
SNDS
SRCC, SRCE,
SRDC, SRDE,
SRDS
RIDE Data Element Description
The date of a Single Event Violation; it is only used for
Single Event Violations.
[f the single event violation ocurred over multiple days, the
date the ocurrence began.
[f the single event violation ocurred over multiple days, the
date the ocurrence ended.
The type of RNC detected. It can be entered automatically
3y the system or it can be entered manually.
The date that RNC was detected. It can be entered
manually or automatically. In cases in which RNC is
detected by ICIS NPDES, the detection date entered
will vary according to the type of violation detected.
The RNC status (i.e., noncompliant, resolved pending,
waiting resolution, resolved) of the violation. It can be
entered manually or automatically by the system.
The date RNC was marked to its current resolution status.
[t can be entered manually or automatically.
System
Required
Yes
No
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
Program Reports
2a-19
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Sub-Area
Basic Info
Basic Info
Biosolids
Bios oil ds
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
CAFO
Data Element Name
Report Received/ Event
Date:
NPDESID
Report Coverage End
Date
Slumber of Report Units
Animal Types
Animal: Other
Total Number
Discharges During Year
from Production Area
Solid Manure or Litter
Generated
Liquid Manure or
Wastewater Generated
Liquid Manure or
Wastewater Transferred
Solid Manure or Litter
Transferred
Does the facility have
an NMP developed or
approved by a certified
planner?
Total Number of Acres
Identified by NMP
The total number of
acres used for land
application in past 1 2
months
PCS equivalent
(if available)1
PSED, DTRC
NPID
RIDE Data Element Description
The date the report was received.
The unique identifier for an activity performed at or related
to a particular site.
The date that report coverage ends.
The number of months that the report covers.
The unique code/ description that identifies the operation's
applicable animal sector(s).
The free-form text field to describe the operation's
applicable animal sector if Other is selected for Animal
Type Code.
The total number of each type of livestock at the facility.
The flag indicating if there is any discharge from the
production area during the year.
The total amount of manure in tons generated annually by
he facility.
The total amount of manure in gallons generated annually
ay the facility.
The number of gallons of manure or litter produced by the
CAFO that will be transferred to other persons.
The number of tons of manure or litter produced by the
CAFO that will be transferred to other persons.
The yes/no flag indicating whether the facility has Nutrient
Vlanure Management Plan developed or approved by a
certified planner.
The number of acres the existing NMP covers.
The total number of acres used for land application in past
12 months.
System
Required
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comment
with Biosolids Permit
Component
with Biosolids Permit
Component
with a CAFO Permit Component
with CAFO Permit Component
with CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
with a CAFO Permit Component
2a-20
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Sub-Area
CSO
cso
cso
cso
Pretreatment
Pretreatment
Pretreatment
Data Element Name
Permitted Feature
[dentifier
Location Street Address
Longitude
Latitude
Pretreatment
Performance Summary
Start Date
SIUs
SIUs Without Control
Mechanism
PCS equivalent
(if available)1
PSSD
RIDE Data Element Description
The unique identifier for the permitted feature number
entered by the user for the CSO.
The street address location of the overflow.
The measure of the angular distance on a meridian east or
west of the prime. Entered in either Decimal Degrees or in
Degrees Minutes Seconds; stored in decimal degrees.
The measure of the angular distance on a meridian north or
south of the equator. Entered in either Decimal Degrees or
in Degrees Minutes Seconds; stored in decimal degrees.
The date on which the Pretreatment Performance Summary
Report starts.
The total number of SIUs.
The number of SIUs for which a current control
mechanism is required but not yet issued or has expired, as
reported on the annual report.
System
Required
No
Yes, if Permitted
Feature Identifier
or Lat/long info is
not entered
Yes, if CSO
Overflow
Location Street
Address or
Permitted Feature
Identifier is not
entered
Yes, if CSO
Overflow
Location Street
Address or
Permitted Feature
Identifier is not
entered
Yes
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Comment
with a CSO Permit Component
with a CSO Permit Component
with a CSO Permit Component
with a CSO Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
2a-21
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Sub-Area
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Data Element Name
SIUs Not Inspected
SIUs Not Sampled
SIUs in SNC with
Pretreatment Standards
SIUs in SNC with
Reporting
Requirements
Violation Notices
Issued to SIUs
Administrative Orders
Issued to SIUs
Civil Suits Filed
Against SIUs
Criminal Suits Filed
Against SIUs
CIUs
Pass-Through/
[nterference Indicator
Date of Most Recent
Technical Evaluation
for Local Limits
Date of Most Recent
Adoption of
Technically Based
Local Limits
PCS equivalent
(if available)1
VINO (not
WENDB),
FENF
ADOR (not
WENDB),
FENF
CIVL (not
WENDB)
GRIM (not
WENDB), JUDI
RIDE Data Element Description
The number of SIUs not inspected, as reported on the
annual report.
The number of SIUs not sampled, as reported on the
annual report.
The significant industrial users in SNC with pretreatment
standards, as reported on the annual report.
The significant industrial users in SNC with reporting
requirements, as reported on the annual report.
The number of formal notices of violation or equivalent
actions that have been issued to SIUs. Notices do not
include AOs (which are defined as a formal notice to the
user of violations and requires specific actions with specific
dates to address those violations. AOs may include
aenalties.)
The number of administrative orders issued to SIUs. An
Adminstrative Order (AO) is defined as a formal notice to
the user of violations and requires specific actions with
specific dates to address those violations. AOs may includf
aenalties.
The number of civil suits filed against SIUs, as reported on
the annual report.
The number of criminal suits filed against SIUs, as reportec
on the annual report.
The total number of CIUs.
The flag indicating if there have been any incidents of pass-
through or interference at the POTW in the past year, as
reported on the annual report.
The date on which the Pretreatment Control Authority has
technically evaluated the need for local limits.
The date of most recent approval of technically based local
imits for pollutants by Pretreatment Approval Authority.
[f 1 or 2 local limits are updated at a time (on-going), the
.atest adoption date (approval) would be the date of the last
approval, even if it was for only one pollutant.
System
Required
No
No
No
No
No
Yes
No
No
No
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Comment
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
2a-22
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Program Reports
Sub-Area
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Pretreatment
Data Element Name
Local Limits Pollutants
Removal Credits
Application Status
Date of Most Recent
Removal Credits
Approval
Removal Credits
SIUs in SNC Published
in Newspaper
Industrial Users (lUs)
from which Penalties
lave been collected
SIUs in SNC with
Pretreatment Schedule
PCS equivalent
(if available)1
SVPU
lUPN
SSNC
RIDE Data Element Description
This is the list of the pollutants for which local limits were
derived, not at the outfall but at the headworks.
The status of the application for removal credits.
This is the date the application for removal credits
was approved.
This field contains a list of pollutants for which
removal credits were granted.
The number of significant industrial users in SNC
aublished in the newspapers, as reported on the annual
report.
Number of lUs (not SIUs) from which penalties have been
collected, as reported on the annual report.
The number of Significant industrial users in SNC with
Pretreatment schedule, as reported on the annual report.
System
Required
Yes, if a date is
entered for Date
Adoption of
Technically
Based Local
L units
No
Yes, if the
Removal Credits
Application
Status is
"approved".
Yes, if the
Removal Credits
Application
Status is
"approved".
No
No
No
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
General
Permit
Covered
Facility
Comment
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
with POTW and Pretreatment
Permit Component
ENFORCEMENT DATA ELEMENTS
Enforcement Action
Enforcement Action
Enforcement Action
Basic Info
Basic Info
Basic Info
Enforcement Action
Identifier
Forum
Enforcement Action
Type
ERFN, CSFN
ENAC, EKAC
ENAC
The number of the Enforcement Action; for a judicial
action, the number as referred to by the Court where the
action was filed. This number is also used to link
compliance schedules to enforcement actions.
This is the legal forum in which the Enforcement Action is
brought. For Administrative Formal, the action is brought
before an administrative body or tribunal.
A description that uniquely identifies the type of
enforcement action (i.e., civil judicial, bankruptcy). For
administrative enforcement actions, the type is the statute
section authorizing the action.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Only for Federal and State
Formal Enforcement Actions
2a-23
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Action
Sub-Area
Basic Info
Basic Info
Basic Info
Basic Info
Data Element Name
Programs Violated
Reason for deleting
enforcement action
Violation Code
Violation Date
PCS equivalent
(if available)1
ENAC
EVTP, ESVC,
ECVC
EVMD, ECVD,
ESVD
RIDE Data Element Description
The code that identifies the program associated with an
activity.
Reason for deleting enforcement action.
The code/ description identifying which type of Violation
las occurred (e.g., D80 = Required Monitoring DMR
Value Non-Receipt, E90 = Effluent Violation, C20 =
Schedule Event Achieved Late).
[f there is a Single Event Violation, use Single Event
Viuolation Date; if DMR reporting violation, use DMR
Due Date; if DMR measurement violation, use Monitoring
Period End Date; if Permit Schedule violation, use Permit
Schedule Date; if a Compliance Schedule violation, use
Compliance Schedule Date.
System
Required
Yes, except for
Federal actions
Yes, if deleting
action.
Yes
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Comment
System -generated for Federal
actions, required for all State
actions.
Only for Formal Enforcement
Actions
Final Orders
Final Orders
Final Orders
Final Orders
Final Orders
Basic Info
Basic Info
Basic Info
Basic Info
Final Order Type
Violation Code
Violation Date
Final Order Issued/
Entered Date
ENAC, EKAC
EVTP, ESVC,
ECVC
EVMD, ECVD,
ESVD
ENDT, EKDT
A code/ description that uniquely identifies the regulatory
instrument used by the EPA to settle the Enforcement
Action.
The code/ description identifying which type of Violation
has occurred (e.g., D80 = Required Monitoring DMR
Value Non-Receipt, E90 = Effluent Violation, C20 =
Schedule Event Achieved Late).
If there is a Single Event Violation, use Single Event
Viuolation Date; if DMR reporting violation, use DMR
Due Date; if DMR measurement violation, use Monitoring
Period End Date; if Permit Schedule violation, use Permit
Schedule Date; if a Compliance Schedule violation, use
Compliance Schedule Date.
The civil case date the Final Order is signed by the
presiding Judge and entered by the Clerk of the Court; it is
the date the Clerk stamps on the document. For an
Administrative Formal EA, this is the Final Order Issued
Date; for a Judicial EA, this is the Final Order Entered
Date.
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Only for Formal Enforcement
Actions
Only for Formal Enforcement
Actions
Only for Formal Enforcement
Actions
Only for Formal Enforcement
Actions
Penalties
Penalty
Basic Info
Cash Civil Penalty
Amount Required-By
Statute
APAM
APPA
For civil judicial Enforcement Actions, the dollar amount
of the penalty assessed against the defendant(s) as specified
in the final entered Consent Decree or Court Order. For
Administrative Enforcement Actions, it is the dollar
amount of the penalty assessed in the Consent/Final Order.
No
Yes
Yes
Yes
Compliance Schedules
Compliance Schedule
Compliance Schedule
Schedule
Schedule
Compliance Schedule
Number
Schedule Descriptor
CSCH, VCSN,
EVSN
A two-digit number which in combination with the
Schedule Type and NPDES ID uniquely identifies a
Compliance Schedule.
The code/ description indicating the type of Narrative
Condition applies for the schedule.
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
System -generated for web users;
RIDE for batch users .
2a-24
-------
APPENDIX2a: DETAILED RIDE TABLE
April 30, 2007 DRAFT
Area
Compliance Schedule
Compliance Schedule
Compliance Schedule
Compliance Schedule
Sub-Area
Event
Event
Event
Event
Data Element Name
Schedule (Start) Date
Actual Date
Report Received Date
Schedule Event
PCS equivalent
(if available)1
DISC, ERDT,
CVDT
DTAC
DTRC
EVNT, CVEV,
EVEV
RIDE Data Element Description
The date the event is scheduled to be occur (i.e., the due
date).
The actual date on which the Compliance Schedule event
occurred.
The date the regulatory agency received the Compliance
Schedule report.
The unique code/ description that identifies the Compliance
Schedule event
System
Required
Yes
No
No
Yes
Permit Type in ICIS-NPDES
Unpermitted
Facility3
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Permit Records
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Yes
Yes
Yes
Yes
Comment
Milestones/ Sub-activities
Milestones/ Sub-
activities
Milestones/ Sub-
activities
Basic Info
Basic Info
Sub Activity Type
Actual Date
ENAC, ENST,
APHR,APAP
ENDT, APFO,
ESDI, APPC,
APAF
A code/ description that uniquely identifies a type of sub
activities and/or milestones in the lifecycle of an
enforcement action, such as "complaint filed" or "action
closed".
The date on which the milestone was achieved/sub activity
was conducted.
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
2a-25
-------
APPENDIX2b: ADDITIONAL FEDERAL RIDE
April 30, 2007 draft
1. This column provides the PCS acronyms that correspond to each RIDE element. If blank, there is no known equivalent. Also, the PCS acronyms represent WENDB elements required in PCS, unless otherwise noted.
2. From the ICIS-NPDES Detailed Design Document (page 4-2): "Data elements are marked as system required when entry of the data element is required by ICIS-NPDES in order for auser to add aparticular record into the system... If [system-]required d;
-e not entered, ICIS-NPDES will reject the transaction."
3. From the ICIS 2.0 Users Guide (Permits section): "Unpermitted facilities are records established in ICIS to allowfor tracking of activities (e.g., inspections and enforcement actions) that are associated with facilities that do not have [NPDES] permits. They may not contain narrative conditions, schedules, or limits." I
apply to facilities covered by a state program that is "broader in scope" than the approved NPDES program (under 33 U.S.C. g 1342(b)). Except for SIUs in non-preatreatment cities, the facility, compliance monitoring, and enforcement datafor unpermitted facilities is only RIDE if there has been aformal enforcement a
order or an informal enforcement action that addressed SNC. For SIUs in non-pretreatment cities, RIDE is expected. Examples of unpermitted facilities include SSS satellite systems and AFOs that, after inspection, are determined to be CAFOs requiring aNPDES permit.
'ata entry requirements do not
;tion, an administrative penalty
Note: This is a list of additional RIDE exclusively for federal users and should be enterediH addition to the RIDE listed in Appendix 2a. This list does not yet include all federal data entry requirements.
Area
Sub -Area
Data Element Name
PCS equivalent
(if available)1
RIDE Data Element Descrq>titm
System
Required2
Information
Source
Regulatory
Citation
Data Use
Permit Typein ICIS-NPDES
Unpermitted
Facility3
Standard/ Individual/
Industrial User Permits &
Associated Perm it Records
Master
General
Permits
General
Permit
Covered
Facility
Comment
PERMIT DATA ELEMENTS
Permit
Permit
Permit
Basic Info
Basic Info
CAFO
Major/Minor Status
Indicator
Major/Minor Status
Start Date
Number of Acres of
Contributing Drainage
from Production Area
MADI
PTAC
Initially system generated (defaults to Minor) and up datable
only by HQ users
The date that the Permit became its current Major/Minor
status Initially system- generated to match effective date
-ฐd"1ฐ
Yes
Yes
No
Major Minor
Rating Sheet
Rating Sheet
Annual Report
122.2/CWA
301(d), 304(b),
and 304(m)
im
122.23
NPDES universe inventory track ing/ NPDES Mgmt
Report (PER)/ ECHO/ OTIS/ ANCR/ WL/
Accomplishments reporting /ELG Annual Review
NPDES universe inventory track ing/ NPDES Mgmt
Report (PER)/ ECHO/ OTIS/ ANCR/ WL/
Accomplishments reporting
areas
Yes
Yes
Yes
Ye,
Yes
Yes
Only EPA HQ can enter this field
EPA
Only EPA HQ can enter this field
EPA
with CAFO Permit Component
COMPLIANCE MONITORING DATA I
Monitoring Activity
Monitoring Activity
Monitoring Activity
Compliance
Monitoring Activity
Monitoring Activity
Monitoring Activity
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
CAFO
Region
If state, local, or tribal
lead, did EPA assist?
If Joint, what was the
purpose of the
participation of the
other party?
Which party had the
lead?
Federal Statute
Violated
Number of Acres of
Contributing Drainage
from Production Area
INSP
INSP
The code/ description that represents the EPA Region
The flag indicating whether the EPA assisted with an
lead
The flag indicating who is the lead of the joint inspection
A code that uniquely identifies the law that is authorizing th
activity orbemgviolated
Nu^.f^^du^^^
Yes
No
Yes
Yes
Yes
No
3560
3560, ICDS
Inspection Form
3560, ICDS
3560, ICDS
Inspection Report
App./NOI;
Inspection
none
CWA 308
CWA 308
CWA 308
CWA 308
122.23
NPDES Mgmt Report (PER)/ ECHO/ OTIS/
Accomplishments reporting
DataQA
ECHO/ OTIS/ WL/ Accomplishments reporting
Accomplishments reporting
Supports enforcement and compliance monitoring
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Federal only
RIDE if "Compliance Monitoring
Agency Type" is not "EPA"
RIDE if "Was this a State,
Federal or Joint(State/Federal)
(State/Federal)"
RIDE if "Was this a State,
Federal or Joint(State/Federal)
Inspection1?" is "Joint
(State/Federal)"
sy!lmg_ซ^
"ซ ฐP
ENFORCEMENT DATA ELEMENTS
Enforcement Ac,,on
Enforcement Ac,,on
Enforcement Act.on
Enforcement Action
Basic Info
Basic Info
Basic Info
Basic Info
Enforcement Action
Comment,
Federal Statutes
Violated
Law Sections Violated
ECM1-ECM10
(not WENDB)
^E^^^""^^"
feld
A code that uniquely identifies the law that is authorizing th
activity or being violated
The Section(s) of law violated and cited in the action
Yes, except for
state actions
No
Yes
Yes, except for
State actions
User-defined, can
be facility name
User-defined,
based on
administrative
record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
CWA Seed on 309
CWA Seed on 309
CWA Section 309
CWA Section 309
Accomplishments reporting
DataQA
-
Accomplishments reporting
Yes
Yes
Ye,
Yes
Yes
Yes
Yes
Yes
Ye,
Yes
Ye,
Yes
Federal only
Only for Federal Formal
Enforcement Actions
Only for Federal Enforcement
Only for Federal Enforcement
Actions
-------
APPENDIX2b: ADDITIONAL FEDERAL RIDE
April 30, 2007 draft
Area
Enforcement Ac,,on
Enforcement Action
Enforcement Action
Enforcement Action
Enforcement Ac,,on
Enforcement Action
Enforcement Ac,,on
Enforcement Action
Sub -Area
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Gov contacts
Gov contacts
Gov contacts
DataElementName
Priorities
Respondents
Defendants
Summary /Non-
Description
Pollutants
Violation Type
Affiliation Type
First Name
Last Name
PCS equivalent
(if available)1
EVTP
RIDE Data Element Descrq>titm
Regional or Core
The name of the defendant, or respondent associated with
the Enforcement Action
^so7me^o oA"it co^d be re^ed as a first
The ICIS internal identifier for a substance.
A unique code identifying the type of violation.
The way that the contact is affiliated with the activity
'
=* .t.n.d,,,dusl
System
Required2
Yes
Yes, except for
State actions
Yes
Yes
Ye,
Yes, for Federal
Formal
Enforcement
Actions
Yes, for Federal
Formal
Enforcement
Actions
Yes, for Federal
Formal
Enforcement
Actions
Information
Source
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Regulatory
Citation
CWA Section 309
CWA Section 309
CWA Section 309
CWA Section 309
CWA Section 309
CWA Section 309
CWA Section 309
CWA Section 309
Data Use
-
Accomplishments reporting
Accomplishments reporting
DataQA
A~
DataQA
DataQA
DataQA
Permit Typein ICIS-NPDES
Facility3
Ye,
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Standard/ Individual/
Industrial User Permits &
Associated Perm it Records
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Master
General
Permits
General
Permit
Covered
Facility
Ye,
Yes
Yes
Yes
Yes
Yes
Ye,
Yes
Comment
Only for Federal Formal
Only for Federal Formal
Only for Federal Formal
Only for Federal Formal
Enforcement Actions, forNPDES
Only for Affiliation Type "Lead
Technical Contact" and/or "Lead
Attorney" for Federal Formal
Only for Affiliation Type "Lead
Only for Affiliation Type "Lead
Technical Contact" and/or "Lead
Attorney" for Federal Formal
Enforcement Actions
Final Orders
Final Orders
Final Orders
Final Orders
Final Orders
Final Orders
Milestones/ Sub-activ
Milestones/ Sub-
activities
Basic Info
Basic Info
Basic Info
Basic Info
Basic Info
Final Order Name
Respondents/
Defendants
Federal Statutes
Violated
Final Order Lodged
Date
Violation Type
EVTP
action as assigned by the lead EPA attorney for federal
^r^rr-1
A code that uniquely identifies the law that is authorizing th
activity or being violated
The date the settlement document is given to the clerk of th<
court for lodging in the district court, it is the date the clerk
stamps en the document (Federal judicial EA's only )
A unique code identifying the type of violation
Yes
Yes
Yes
Yes
Yes
User-defined,
based on
enforcement
action/
administrative
record
Enforcement
Action/
Administrative
Record
Enforcement
Action/
Administrative
Record
Administrative
Record
Enforcement
Action/
Administrative
Record
CWA Seed on 309
CWA Section 309
CWA Section 309
CWA Section 309
CWA Section 309
Accomplishments reporting
Accomplishments reporting
A~
Accomplishments reporting
Accomplishments reporting
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Ye,
Yes
Yes
Only for Federal Formal
Only for Federal Formal
Enforcement Actions
Only for Federal Formal
Only for Federal Judicial
Enforcement Actions when the
Only for Federal Formal
Enforcement Actions, forNPDES
es
Basic Info
Enforcement Action
Resolution Type
resolved
Yes, when
enforcement
action.
Enforcement
Action/
Administrative
Record
CWA Seed on 309
DataQA
Yes
Yes
Yes
Only for Federal Formal
Enforcement Actions, forNPDES
-------
APPENDIX 3, April 30, 2007 DRAFT
RIDE Data Entry Considerations by Program Area
Since January 2006, EPA and the States have been actively involved in renewed discussions which have included considerations regarding the
expectations for data entry or transfer into ICIS-NPDES for each program area and possible phasing of selected data, particularly for non-major
facilities. The Resources workgroup formed by the ICIS-NPDES Expanded Steering Committee produced a RIDE Data Entry Estimate Model,
which was used to estimate RIDE data entry resources (in full-time equivalents [FTEs]) both nationally and for nine individual states. A brief
synopsis of the national assumptions and results of the RIDE Data Entry Estimate Model for the various program areas is provided in the chart
below, with the percent of total RIDE data entry based upon the RIDE Data Entry Model estimate. With the exception of pretreatment, PCS was
not capable of providing sufficient information regarding these program areas.
Program Area
Biosolids
Combined Sewer
Systems (CSSs)
Concentrated
Animal Feeding
Operations (CAFOs)
Pretreatment
Separate Sanitary
Sewer Systems
(SSSs)
Stormwater (SW)
Estimated Universe
6,000 sludge-only facilities
821 CSSs, with 8,924 combined
sewer outfall locations
13,800 large or medium CAFOs
with permits; 224,217 AFOS or
CAFOs without permits
1,464 approved local programs
20,000 sanitary sewer overflows
per year
280 Phase I MS4s, 7,500 Phase II
MS4s, 100,000 Phase I SW
industrial non-const., 10,000
Phase II SW industrial non-const.,
100,000 Phase I SW const.,
150,000 Phase II SW const.
% of Total
RIDE Data
2%
<1%
1%
Mostly
WENDB in
PCS;
-------
APPENDIX 3a: EPA RIDE Data Entry Model
Biosolids
Stormwater
3%
AFO/ CAFO CSO,SSO, new
1 % ,- Pretreatment
Non-Major non-
Stormwater General
Outfalls, Limits, & DMRs
8%
Other Required Non-
Major Individual
Outfalls, Limits, & DMRs
34%
Other new requirements
1%
Non-Major Individual
Outfalls, Limits, & DMRs
already being entered
35%
Note: Full Circle represents 1.8 FTEs per State per year
(based on February 2007 revised model)
The striped slices reflect data that is being entered into PCS/ ICIS-NPDES now.
April 30, 2007 DRAFT
-------
APPENDIX 4, April 30, 2007 DRAFT
Key National Targets for Data in ICIS-NPDES
A phased transition period allows permitted authorities (States, Territories, Tribes and EPA
Regions) to become familiar with the ICIS-NPDES system, make program adjustments if necessary,
and initiate data entry or transfer of the RIDE into ICIS-NPDES. The transition period applies
primarily to that RIDE for which WENDB equivalents did not exist in PCS. EPA recommends that
States, Territories and Tribes develop transition plans to promote a timely and efficient move from
PCS to ICIS-NPDES. The key national targets for data entry that should be incorporated into the
transition plans for all current and prospective users of ICIS-NPDES are described below.
By August 1, 2007, all NPDES-authorized States, Territories and Tribes should begin to
develop an ICIS-NPDES transition plan that includes a strategy to fully enter all RIDE within the
target dates specified. The draft transition plan for each individual State, Territory and Tribe
should be submitted no later than the deadlines stated below to the EPA Region for review and
approval. Hybrid and non-direct (batch) users have been allocated four additional months to review
the ICIS-NPDES XML schemas as they develop their transition plans. This also allows some
phasing of the Regional workload to review these plans. EPA Regions which are responsible for
direct implementation of the NPDES program in a non-authorized State or Tribal area shall submit
their own transition plans to EPA Headquarters by December 1, 2007. EPA will review and
approve adequate plans within three months of receipt.
Direct
Users
8/1/2007
12/1/2007
3/1/2008
Hybrid/ Batch
Users
8/1/2007
4/1/2008
7/1/2008
Target
- Begin development of ICIS-NPDES transition plans
- Submit State and Tribal transition plans to the EPA Regions for review and approval. (Regions
that are developing transition plans for States and Tribes that are not authorized for the NPDES
program will submit such plans to EPA HQ for review and approval.)
- Complete EPA review and approval of all transition plans for States, Tribes and EPA Regions.
In 2006 and 2007, EPA worked with the States - via the Expanded Steering Committee, and
its associated Resources and Matrix Workgroups to further refine the RIDE list and to closely
examine key concepts associated with ICIS-NPDES. EPA has used the information and products
from those efforts to develop the national data targets for the early years of implementation of the
ICIS-NPDES Policy Statement. These national data targets (presented in the table below) should be
incorporated into the transition plans for each State, Territory, Tribe or Region. The target dates in
the table below apply to all States, with the understanding that all dates may be extended up to four
months after a State migrates to ICIS-NPDES.
The transition plans should also ensure that data associated with non-DMR compliance
monitoring (e.g., inspections), single event violations, enforcement actions, penalties and
compliance schedules should be entered or transferred into ICIS-NPDES as those events occur
(after migration from PCS to ICIS-NPDES). The transition plans should also ensure that
appropriate linkages between the data for these compliance monitoring and enforcement items are
also entered into ICIS-NPDES. In addition, the transition plans should ensure RIDE data entry or
transfer to ICIS-NPDES is consistent with all requirements of Sections E, F, and G of this Policy
Statement and with the RIDE list (in Appendix 2a; for Federal users, Appendices 2a and 2b). A
transition plan template is provided in Appendix 5.
4-1
-------
DETAILED TARGETS FOR STATES, TRIBES, AND REGIONS
By the dates below or within four months of migration to ICIS-NPDES (whichever is later), all users are expected to meet these national data targets.1
Target (these represent 98% data completeness unless otherwise specified)
Facility/ Permit Information
Basic Information - WENDB
Facility Latitudes/Longitudes3
Special Program Area Permit Components4 and other new (non- WENDB) RIDE
Permitted Feature Data3, Limit Sets, Limits andDMRs5
Traditional Universe
Stormwater Industrial permits
Biosolids
Narrative Conditions (Permit Schedules were WENDB for majors)
Inspections
Traditional Universe (i.e., traditional majors and non-majors, excluding wet
weather program areas) and Pretreatment - (were WENDB in PCS)
Special Program Areas
Violations
Permit/ Compliance Schedule and DMR violations
Single Event Violations
Program Reports
Existing WENDB (Pretreatment)
New Special Program Areas (Biosolids, CAFOs, CSOs)
Enforcement Actions (Were WENDB for majors)
Majors
Individual Non-Majors
General Non-Majors2
8/1/2007
8/1/2007
5/1/2008
8/1/2007
N/A
5/1/2008
8/1/2007
5/1/2008
12/1/2008
>50% (with an emphasis on those
facilities located in priority
watersheds) by 9/1/2008.
Enter data for remaining facilities 2
years after NetDMR is implemented
N/A
12/1/2008
No later than 8/1/20 10
5/1/2008
12/1/2009
>25% (with an emphasis on those
facilities located in priority
watersheds) by 9/1/2009.
Enter data for remaining facilities 3
years after NetDMR is
implemented.
12/1/2009
12/1/2009
No later than 8/1/2010
Entered as they occur
System-generated based on data
Entered as they occur
8/1/2007
8/1/2007 6
N/A
No later than 8/1/20 10
Entered as they occur
1 EPA may revise these dates for batch and hybrid users to address any unforeseen issues related to the fmalization of the ICIS-NPDES XML schema by the Integrated Project Team.
2 RIDE for facility, permit, compliance monitoring, violations and enforcement data for SSS satellites and Stormwater-Construction sites is not expected except if the State or Tribe issues a formal
enforcement action, administrative penalty order, or other informal enforcement action which addresses the stormwater SNC. In this case, the data should be entered as the events occur.
3 If this locational data (latitude, longitude, source map scale number, horizontal accuracy measure, horizontal collection method, horizontal reference datum, and reference point) currently are not
collected, the permitting authority may wait until permit reissuance to enter or transfer this particular data.
4 These special program area elements apply to CAFOs, Biosolids, CSOs, Pretreatment, POTW, and Storm Water facilities.
5 Note that some permits do not have DMR requirements; for these permits, limit, limit set, and DMR data entry will not be necessary.
6 Pretreatment Performance Summary Data is currently WENDB for major facilities and for minor facilities that are PL 92-500 Construction Grant recipients.
4-2
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APPENDIX 5, April 30, 2007 DRAFT
Template for a Transition Plan
As described in Sections F and G of this Policy Statement, the transition plan and
target schedule for authorized States, Territories and Tribes will be reviewed and
approved by EPA Regions at the Division Director level (Enforcement and Water) within
three months of submission to EPA. Similarly, transition plans and target schedules for
non-authorized States, Territories or Tribes will be reviewed and approved by EPA
Headquarters within three months of Regional submission.
I.
II.
The transition plans should include the following information:
Name of State/Territory/Tribe/Region:
Type of User:
Direct
Non-direct
Hybrid/Combination
(If hybrid/combination, please provide short explanation).
III. Number of facilities in each of these categories:
Traditional
majors
Traditional
individual
non-majors
Traditional
general-
permitted
non-majors
Biosolids
u
Approved
pretreatment
programs
SIUs in non-
pretreatment
cities
CO
CO
U
CO
CO
CO
CO
Non-
construction
industrial
stormwater sites
Stormwater
construction
sites (annually)
IV. Strategy/Approach:
Provide a short description of the State, Territorial, Tribal or Regional plan for
meeting national RIDE reporting targets in ICIS-NPDES within the transition period.
Each of the following items should be covered in the strategy description:
A. Overall implementation strategy: by permit type, by watershed, by prioritization
of minors, other;
B. Gap analysis to determine areas where RIDE currently are not collected or not
available electronically (To assist in this effort, EPA will generate a report to
indicate how well-populated the various WENDB data elements are in PCS);
C. Description of business processes that need to be changed to address data gaps
and to ensure that RIDE flows to ICIS-NPDES. How will this be done? Will
data entry be centralized? Will spreadsheets or other tracking be phased into
ICIS?
D. If non-direct users or hybrid/combination users, description of changes needed to
be made to the data system of the State, Territory or Tribe;
5-1
-------
E. Incorporation of national data entry targets (as identified in Appendix 5) into the
strategy and the schedule;
F. Description of the amount of grant money that has been made available to the
State, Territory or Tribe for the transition from PCS to ICIS-NPDES and which
activities are to be accomplished with the grant money;
G. Description of additional training or equipment that may be necessary;
H. Description of impacts on other data systems within the State, Territory or Tribe;
and
I. Description of quality assurance (QA) procedures that will be used to ensure data
quality and timeliness.
V. Schedule:
This schedule should be developed with reference to Appendix 4 of the Policy
Statement (Key National Targets for Data in ICIS-NPDES). The schedule should
include key targets for RIDE data entry, national data entry targets and data system
modifications necessary to directly use, link or transfer data to ICIS-NPDES.
Within the national data entry targets, the permitting authority has flexibility in
the prioritization approach that is used for data entry or data transfer to ICIS-NPDES.
One option for prioritizing RIDE data entry or transfer into ICIS-NPDES is to prioritize
data entry for facilities located in priority watersheds; this approach is particularly
encouraged in the possible phasing of the data entry of DMRs for non-major facilities (as
discussed in Section F of the Policy Statement). Another prioritization option would use
permit components for specific program areas, such as CSSs, SSSs, pretreatment,
biosolids, stormwater-MS4s, stormwater-industrial (non-construction), stormwater-
construction and CAFOs. Another approach would be to enter all available RIDE data
for facilities covered by major individual permits, then those covered by non-major
individual permits, non-stormwater general permits and stormwater general permits.
Although States, Territories or Tribes may exercise flexibility regarding which program
areas or permit types are made available in ICIS-NPDES first, any such prioritization
effort should still ensure that national data targets are met.
As an example, the attached table is a suggested format for a Data Entry Schedule
Chart to be included in the Transition Plan for each State, Territory, Tribe or Region if
using a permit type prioritization for RIDE data entry or transfer into ICIS-NPDES:
5-2
-------
DATA ENTRY SCHEDULE CHART: DETAILED TARGETS
Target (these represent 98% data completeness unless otherwise specified)
Facility/ Permit Information
Basic Information -
(expected to be available without delay; WENDB data migrated from PCS)
Facility Latitudes/Longitudes
Special Program Area Permit Components and other new (non- WENDB) RIDE
Permitted Feature Data, Limit Sets, Limits andDMRs
Traditional Universe
Stormwater Industrial permits
Biosolids
Narrative Conditions (Permit Schedules) (were WENDB for majors)
Inspections
Traditional Universe and Pretreatment -
(historical data will be migrated from PCS, where such data was WENDB)
Special Program Areas
Violations
Permit/ Compliance Schedule and DMR violations
Single Event Violations
Program Reports
Existing WENDB (Pretreatment)(not a new requirement)
New Special Program Areas (Biosolids, CAFOs, CSOs)
Enforcement Actions (previously was WENDB for majors only)
Majors
Individual Non-Majors
General Non-Majors
5-3
-------
VI. Resources:
Explain resource implications, in terms of staffing, training, other support as well
as anticipated cost savings from electronic reporting. States are encouraged to use the
RIDE Data Entry Estimate Model to estimate annual ICIS-NPDES data entry resources
for the State. To the extent known, explain how these resource estimates may shift over
the initial few years.
VII. Linkages
For hybrid or non-direct users, provide sufficient detail as to what data will be
directly entered into ICIS-NPDES (if any), and what data will be shared or transferred to
ICIS-NPDES using ICIS-NPDES XML schema, including any phasing of data
exchanged and frequency. In addition, the transition plan should clearly indicate what
measures will be taken to ensure that entry of associated linkages between permits,
inspections, violations and enforcement data will occur and be present in ICIS-NPDES.
VIII. Contacts
Identify key system contacts, including: system administrator; data steward; data
entry personnel; responsible manager; other agency contacts. Please specifically identify
the key contact regarding the development and implementation of the transition plan.
5-4
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APPENDIX 6, April 30, 2007 DRAFT
Key ICIS-NPDES Roles and Responsibilities
Defining and maintaining clear roles and responsibilities are essential to
managing a decentralized database such as ICIS-NPDES. The table below summarizes
key management responsibilities for each group (NPDES-authorized States, Territories
and Tribes, EPA Regions, OECA, OW, and OEI) in maintaining a successful system.
Authorized State, Territory or Tribe
1. Attend ICIS-NPDES User Group meetings and conference calls;
2. Develop transition plan and work with the Region during the review process;
3. Enter or transfer data to ICIS-NPDES pursuant to the standards set forth in Sections E, F
and G of this Policy Statement, in the RIDE list and in the approved transition plan;
4. Have complete, accurate RIDE data in ICIS-NPDES within the approved transition
period;
5. Ensure data quality in ICIS-NPDES;
6. Establish, maintain and implement clear ICIS-NPDES management agreements;
7. Identify System Administrator and Data Steward;
8. Manage users within the State, Territory or Tribe;
9. Identify training needs for users within the State, Territory or Tribe;
10. Manage, research and correct reported data issues; and
11. Work closely with Regional and OECA/ OW representatives including participating in
ICIS-NPDES workgroups and in major decisions related to ICIS-NPDES through the
system governance bodies.
EPA Region
1. Attend ICIS-NPDES User Group meetings and conference calls as needed;
2. Develop transition plans for non-authorized States, Territories and Tribes; work with
Headquarters during the review process;
3. Enter data pursuant to the standards set forth in Section E of this Policy Statement, in the
Federal RIDE list and in the approved transition plan;
4. Enter NPDES data for non-authorized States, Territories and Tribes in accordance with
Sections E, F and G of this Policy Statement and have complete RIDE data in system
within the approved transition period;
5. Ensure data quality in ICIS-NPDES;
6. Monitor and supplement data entry from States, Territories and Tribes, if necessary;
7. Review and approve transition plans;
8. Review and approve transition plans;
9. Establish, maintain and ensure implementation of clear ICIS-NPDES management
agreements with States, Territories or Tribes, incorporating such agreements into PPAs or
similar documents;
10. Identify System Administrator and Data Steward;
11. Train and manage users;
12. Manage, research and correct reported data issues;
13. Work closely with Regional and OECA/ OW representatives including participating in
ICIS-NPDES workgroups and in major decisions related to ICIS-NPDES through the
system governance bodies; and
14. Provide a source of ICIS-NPDES technical assistance and training.
6-1
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OECA
1. Request appropriate resources to support ICIS-NPDES;
2. Operate and maintain ICIS-NPDES;
3. Evaluate and improve ICIS-NPDES to better ensure customer satisfaction;
4. Provide programmatic knowledge and experience;
5. Assert leadership in ensuring that compliance and enforcement information is kept
current and complete by States, Territories, Tribes and Regions;
6. Resolve issues;
7. Maintain ICIS governance process;
8. Organize national meetings and conference calls;
9. Work closely with OW and Regional, State, Territorial and Tribal representatives and
associations on major decisions related to ICIS-NPDES;
10. Manage user contact lists, sensitive data access, RNC and DMR non-receipt flags, and
develop guidance and reference tables;
11. Monitor State-Region, Territory-Region and Tribe-Region ICIS-NPDES management
agreements;
12. Review and approve transition plans submitted by Regions for non-authorized States,
Territories and Tribes; and
13. Secure and provide training for use of ICIS-NPDES.
OW
1. Work with OECA to ensure the availability of adequate resources;
2. Monitor State-Region, Territory-Region and Tribe-Region ICIS-NPDES management
agreements;
3. Review and approve transition plans submitted by Regions for non-authorized States,
Territories and Tribes;
4. Provide programmatic knowledge and experience;
5. Participate in ICIS-NPDES governance bodies;
6. Assert leadership in ensuring permit information is kept current and complete by States,
Territories, Tribes and Regions;
7. Resolve issues; and
8. Work closely with OECA, Regional, State, Territorial and Tribal representatives and
associations, including participating in ICIS-NPDES workgroups and in major decisions
related to ICIS-NPDES.
OEI
1. Work with OECA to ensure the availability of adequate resources;
2. Manage Exchange Network, ICIS-NPDES XML schema, security protocols, and data
standards (including locational and facility data standards);
3. Work closely with OECA, OW, Regional, State, Territorial and Tribal representatives
on major decisions related to ICIS-NPDES; and
4. Assist in data exchange between States, Territories, Tribes and EPA.
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APPENDIX 7a, April 30, 2007 DRAFT
Definitions of Terms
Authorized State or Tribe
For the purposes of this document, an authorized State or Tribe is a State or Tribal
government which has received NPDES permitting authority from EPA.
Batch data entry
Batch data entry in ICIS-NPDES is the transmission of extensible Markup Language
(XML) data files through the Central Data Exchange into ICIS-NPDES. For comparison,
in PCS, batch data entry occurred via upload of fixed format data files to the mainframe.
Core data
Core data refers to the RIDE information associated with facility, permit, compliance
monitoring, and enforcement data types.
Data element
A specific field or column name in ICIS-NPDES or PCS that contains information when
data is entered.
Direct data entry
This refers to manual data entry by key punching, often in the case where the State, Tribe
or EPA Region is using PCS or ICIS-NPDES as their primary NPDES data management
system.
Direct user State or Tribe
In an NPDES program implemented by an authorized State or Tribe which will use
ICIS-NPDES to manage the NPDES program, direct users manually enter data into
ICIS-NPDES through the keyboard into web screens.
Hybrid State or Tribe
In an NPDES program implemented by an authorized State or Tribe which will use
ICIS-NPDES to manage the NPDES program, hybrid users manually enter some of the
data (usually non-DMR data) into ICIS-NPDES through the keyboard into web screens.
They also electronically transfer the rest of the data (usually DMR data) into
ICIS-NPDES; this electronic method of data entry will likely increase, especially with the
availability of eDMR (electronic DMR) tools, such as NetDMR.
ICIS
The acronym ICIS stands for the Integrated Compliance Information System, developed
by EPA to serve as a national multi-media data system.
7a-l
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Major
A major facility is defined as follows: a major municipal facility has a flow of 1 million
gallons per day or greater, a service population of 10,000 or greater or a significant
impact on water quality; industrial facilities are considered major facilities based on a
rating system that allocates points in various categories, including flow, pollutant
loadings and water quality factors. EPA Regions, States and Tribes also have the
discretion to identify other facilities as major facilities due to environmental concerns.
Non-direct user State or Tribe
Such a State or Tribal NPDES program uses another software system, besides
ICIS-NPDES, to manage the NPDES program and only ensures that data is entered or
transferred to ICIS-NPDES and is available to satisfy national reporting responsibilities
and national program management needs. These States and Tribes are expected to rely
heavily on electronic transfer (batch) using CDX and the Exchange Network, but may
also use keyboard data entry for some purposes, particularly if the State or Tribe database
has not been modified to include all RIDE.
Non-major
The universe of facilities regulated under the NPDES program that are not
"major"facilities. Non-major facilities can also be referred to as "minor" facilities,
although this does not denote a less important status.
PCS
The acronym PCS stands for the Permit Compliance System, which served as the national
database of record for the NPDEs program since 1985.
Program components
Program components refer NPDES permit requirements associated with particular
program areas. In ICIS-NPDES, a group of data elements are available to users to track
program-specific data on Publicly-Owned Treatment Works (POTWs), Combined Sewer
Overflows (CSOs), Sanitary Sewer Overflows (SSOs), Pretreatment, Biosolids,
Stormwater, and Concentrated Animal Feeding Operations (CAFOs).
RIDE
The acronym RIDE stands for the Requisite ICIS-NPDES Data Elements, defined as the
essential national information needed from NPDES-authorized agencies for EPA to meet
the national NPDES national program management, oversight and reporting needs.
Single event violation
A Single Event Violation is a violation of a NPDES permit or regulatory requirement that
is observed or determined by the permitting authority (EPA Region or authorized State/
local/ tribal government), and is distinct from violations that are system-generated (e.g.,
effluent limit violations arising from DMR submission, DMR non-receipt or compliance
schedule violations). An unauthorized bypass or discharge, a violation detected during an
inspection, a narrative violation description reported on a DMR, and a pretreatment
violation are examples of Single Event Violations.
7a-2
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System-required data
Key data elements that are necessary in order to submit information or proceed to the
next screen in ICIS-NPDES.
WENDB
The acronym WENDB stands for the Water Enforcement National Data Base data
elements, identified as the required data elements in the Permit Compliance System
(PCS), which served as the national database of record for the NPDES program since
1985.
Wet weather sources
These are non-traditional NPDES sources which include storm water runoff from
industrial and municipal sectors, discharges from concentrated animal feeding operations
(CAFOs), and overflows from combined and sanitary sewer systems (CSOs and SSOs).
Such sources have been a program priority for EPA's enforcement and compliance
program since 1998.
7a-3
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APPENDIX 7b
Definition of Acronyms
CAFO - Concentrated Animal Feeding Operation
CDX - Central Data Exchange
CFR - Code of Federal Regulations
CSO - Combined Sewer Overflow
CSS - Combined Sewer System
DMR - Discharge Monitoring Report
ECHO - Enforcement and Compliance History Online
ICIS - Integrated Compliance Information System
MS4 - Municipal Separate Storm Sewer System
NPDES - National Pollutant Discharge Elimination System
OC - EPA's Office of Compliance
OECA - EPA's Office of Enforcement and Compliance Assurance
OEI - EPA's Office of Environmental Information
OW - EPA's Office of Water
PCS - Permit Compliance System
POTW - Publicly-Owned Treatment Works
RIDE - Requisite ICIS-NPDES Data Elements
RNC - Reportable Non-Compliance according to 40 CFR ง123.45
SNC - Significant Non-Compliance according to 40 CFR ง123.45
SSO - Sanitary Sewer Overflow
SSS - Sanitary Sewer System
7b-l
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WENDB - Water Enforcement National Data Base
XML - extensible Markup Language
7b-2
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>w
OJ
THE
AIR FACILITY
SYSTEM (AFS)
BUSINESS RULES
COMPENDIUM
compendium was initially compiled in 2003 via the collaborative efforts of
the EPA, its Regions and users of AFS. It is intended to be a living document, to
change when the air compliance/enforcement program changes, and when the
AFS changes.
VERSION 4.1- August 2009
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This Page Intentionally Left Blank
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AFS BUSINESS RULES COMPENDIUM
THE OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE
OFFICE OF COMPLIANCE
ENFORCEMENT TARGETING & DATA DIVISION
DATA INFORMATION SYSTEM MANAGEMENT BRANCH
MEDIA SYSTEMS AND SUPPORT SECTION
AFS Business Rules, Version 4.1
August 2009
Table of Contents
RECORD OF DOCUMENT CHANGES 4
INTRODUCTION 5
SECTION 1: CURRENT MINIMUM DATA REQUIREMENTS (MDRs) 6
SECTION 2: CAA STATIONARY SOURCE CMS POLICY AS IMPLEMENTED IN AFS 10
A. BACKGROUND: 10
B. PLAN IMPLEMENTATION AND AUTO UNKNOWN COMPLIANCE STATUS: 11
C. TRACKING CMS PLANS WITH AFS FIXED REPORTS: 15
D. HISTORIC CMS RECORDS: 16
SECTION 3: USING AFS FOR COMPLIANCE/ENFORCEMENT TRACKING 17
A. PLANT LEVEL RECORDS 17
1. Entering aNew Plant and Identification Numbers into the Database: 17
2. Plant Name: 17
3. Latitude/Longitude: 18
4. SIC/NAIC Codes: 18
5. State Registration Number: 18
6. Governmental Facility Code: 18
7. Portable Sources: 18
8. Archiving Permanently Closed Sources: 18
9. Local Control Region (LCON): 19
B. AIR PROGRAM AND AIR PROGRAM POLLUTANT RECORDS 19
1. Air Programs: 19
a. Air Program Operating Status: 20
b. Applicable Air Program Codes: 20
0 State Implementation Plan (SIP) 20
1 SIP Source under Federal Jurisdiction (FIP) 21
3 Non-Federally Reportable 21
4 Chlorofluorocarbons (CFC) Tracking 21
6 Prevention of Significant Deterioration (PSD) 21
7 New Source Review (NSR) 21
8 National Emission Standards for Hazardous Air Pollutants (NESHAP PART 61) 22
9 New Source Performance Standards (NSPS PART 60) 22
F Federally Enforceable State Operating Permit Program (FESOP) 23
I Native American 23
M Maximum Achievable Control Technology (MACT PART 63) 24
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AFS BUSINESS RULES COMPENDIUM
T Tribal Implementation Plan (TIP) 24
V Title V Operating Permits 24
c. Air Program Subparts: 24
2. Air Program Pollutant Records: 25
a. Pollutant Code or Chemical Abstract Number: 25
b. Classification: 25
c. Compliance Status: 27
d. Attainment/Nonattainment Indicator: 28
C. ACTION RECORDS 29
1. Fields: 29
2. Full Compliance Evaluations (FCEs): 32
3. Partial Compliance Evaluations (PCEs): 34
4. Stack (Performance) Tests: 35
5. Investigations: 37
6. Notices of Violation: 38
7. Administrative Orders: 39
8. Consent Decrees: 40
9. Civil Referrals: 41
10. Civil Actions 42
11. High Priority Violator (HPV) Day Zero 43
12. High Priority Violator (HPV) Lead Changes: 54
13. High Priority Violator (HPV) Addressing and Resolving Actions: 54
14. Non-HPV Day Zero: 57
15. Dropped HPV Cases 57
16. Title V Annual Compliance Certifications Date Due and Received 57
17. Title V Annual Compliance Certification Reviews: 58
18. Tracking Full Compliance Evaluation Pathways in AFS: 59
19. Reporting Non-Applicability Determinations 61
SECTION 4 SECURITY AND AFS 63
A. EPA's SECURITY MEASURES FOR AFS 63
B. AFS CONTINGENCY PLANNING - WHAT TO DO IN A DISASTER 64
C. GUIDELINES FOR HANDLING ENFORCEMENT SENSITIVE DATA 67
SECTION 5 NATIONAL INITIATIVES 68
A. AIR TOXICS INITIATIVE 68
B. OTHER NATIONAL INITIATIVES: 70
SECTION 6 SUGGESTIONS FOR IMPROVING AFS 71
SECTION 7 AFS DOCUMENTATION 74
SECTIONS AFS CONTACTS 75
AFS Business Rules Compendium Revision 4.1 August 2009 Page 2 of 76
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AFS BUSINESS RULES COMPENDIUM
Listing of Appendices
Appendix 1: Compliance Monitoring Strategy Charts
Appendix 2: AFS Plant General Structure/ Data Element Dictionary
Appendix 3a: AFS Regional General Action Types
Appendix 3b: AFS National Action Types Applicable for Tribal Activity
Appendix 3c: AFS National Action Types Allowable as Duplicates Actions
Appendix 4: Listing of Local Control Table Values for AFS
Appendix 5: New Source Performance Standards (NSPS), National Emission Standards for
Hazardous Air Pollutants (NESHAP), and Maximum Achievable Control
Technology (MACT) Air Subpart Tables
Appendix 6: Security and AFS
Appendix 7: Acronyms Used in this Document
Appendix 8: Change/Update Request Form
Appendix 9: AFS Utilities for 2009
Appendix 10: AFS Contingency Planning Data Entry Forms
AFS Business Rules Compendium
Revision 4.1 August 2009
Page 3 of 76
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AFS BUSINESS RULES COMPENDIUM
RECORD OF DOCUMENT CHANGES
Revision #
0
1
2
3
3.1
4.0
4.1
Date
July 2004
July 2005
July 2006
Aug 2007
Sep 2007
Mar 2009
Aug 2009
Summary of Changes/Additions
Initial release of the document
Update: Complete replacement
Various grammatical and editorial updates were made
throughout the compendium. In addition, content updates also
were completed and the following sections have been changed:
Section 2, 3B1, 3B2, and 3C1 1, along with the addition of
Section 4 and Subsections: 3C17, and 3C18. All appendices
were updated with new additions of appendices 3b, 3c, 4, 5, & 6.
Update: Complete replacement. Correction-"Receipt of Stack
Test Report" action type as a Discovery Date action versus PCE,
page 44. Addition of Section 15, Dropped HPV Cases, page 56.
Update: Additional HPV Discovery Date action type of TV
ACC Due/Received, reference pages 49, 51, 52.
Updated MDR Table page 6, new CMS categories for Tribal
sources page 11, new CMS Fixed reports page 15, historic CMS
category codes page 16, updated archive rule page 18, added
new TIP air program code page 24, moved compliance status
value 7 to out of compliance values page 27-28, new optional
stack test actions page 36, included new HPV enhancements and
retrievable acronyms pages 44, added federal Air Toxics
Initiative page 65, added AFS Utilities schedule Appendix 9,
updated all appendices. Updated listing of allowable duplicate
action types (5/22/09)
Added contingency planning documentation to security section
(section 4) and AFS contacts list (section 8). Addition of
Appendix 10: AFS Contingency Planning Data Entry Form
AFS Business Rules Compendium
Revision 4.1 August 2009
Page 4 of 76
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AFS BUSINESS RULES COMPENDIUM
INTRODUCTION
In July of 2003 at the National AFS Workshop in Chicago, IL, draft AFS Business Rules
were introduced to all participants. These draft Business Rules are to become the documentation
for how data is reported and used in AFS.
During the summer and into the fall of 2003, teleconferences with all ten EPA Regions
and interested state and local participants were held to review each page and each record of the
documents. Definitions were fleshed out and descriptions added resulting from the
conversations held. An average of four, one-hour conference calls were held with each Region.
The resulting document was provided to the Air Branch Chiefs for comment, review and
approval.
The information documented in the Business Rules will be used for three important
purposes: to provide all users of the Air Facility System (AFS) with a guide for the interpretation
of data fields, to complete a Closeness of Fit Analysis (COFA) with the Integrated Compliance
Information System (ICIS) in a modernization effort; and for further integration with the
Agency's multi-media information in systems like the Online Targeting and Information System
(OTIS) and the Enforcement Compliance History Online (ECHO) system.
Suggestions for changes or additions to the compendium (please refer to Appendix 8 for
an optional form to be filed out to aid in submitting comments and updates to the compendium)
can be forwarded to:
ปซป An Regional AFS Compliance Manager
< The AFS Helpline, Voice 1-800-367-1044, FAX 860-278-2400, or email to
AFShelpline@trcsolutions.com
< AFS System Administrator, Betsy Metcalf, Voice 202-564-5962, FAX 202-564-0032, or
email to metcalf.betsy@epa.gov
* AFS Security Manager, Akachi Imegwu, Voice 202-564-0045, Fax 202-564-0032, or
email to imegwu.akachi@epa.gov
Suggestions for changes/additions will be distributed among the Regional AFS Compliance
Managers for comment, and then reviewed in the AFS Configuration Control Board. After
approval by the Board, the compendium will be updated.
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AFS BUSINESS RULES COMPENDIUM
SECTION 1: CURRENT MINIMUM DATA REQUIREMENTS (MDRs)
The Clean Air Act (CAA) describes in detail the reporting requirements for agencies
authorized with delegation. EPA maintains several databases that track Air Compliance and
Enforcement activity. AFS is the national repository for air stationary source surveillance and
state enforcement activity. It maintains a universe of sources considered "Federally Reportable".
Federally Reportable sources are those which exceed (Major Sources) or have the potential to
exceed (Synthetic Minor Sources) a pollutant's major emission threshold; operating Part 61
National Emission Standard for Hazardous Air Pollutant (NESHAP) sources regardless of
emission level, sources identified within the Compliance Monitoring Strategy (CMS) plan, any
facility with a formal enforcement action, and any facility with an active HPV. See also
Appendix 7, Acronyms Used in this Document, for the definition of air program acronyms.
Every three years, an effort to document reporting requirements and measure the cost of
data maintenance is completed. The "Information Collection Request (ICR)" is an identification
of information collected by the Air Compliance and Enforcement community for support of the
program. The most recent ICR can be found on the AFS Web Page at:
http://www.epa.gov/compliance/data/svstems/air/afssystem.html
The ICR provides a table of Minimum Data Requirements (MDRs). The following
information provides a version of that document:
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AFS BUSINESS RULES COMPENDIUM
TABLE 1
SUMMARY OF NATIONAL MINIMUM DATA REQUIREMENTS (MDRs)
FOR CLEAN AIR ACT STATIONARY SOURCE COMPLIANCE
Note: Unless otherwise noted, both Regions and states/locals report their data. The reportable
universe of facilities for AFS includes: Major, Synthetic Minor and Part 61 NESHAP Minor
facilities, other facilities identified within the CMS Evaluation Plan, any facility with a formal
enforcement action and any facility with an active HPV. Facilities with formal enforcement
actions (administrative orders, consent decrees, civil or criminal referrals and actions) should be
tracked in AFS until the resolution of the violation, regardless of classification. If a minor source
is included in the CMS universe, has a current enforcement action of <3 years old, or is listed as
a discretionary HPV, it is considered reportable to AFS. Individual regional/state agreements are
not superseded by this listing.
AFS
Identification Acronym
1. Facility Name PNME
2. State STAB/STTE
3. County CNTY
4. Facility Number PCDS
5. Street SIRS
6. City CYNM
7. Zip Code ZIPC
8. SICorNAICSCode SIC I/NIC 1
9. Government Ownership GOVT
10. HPV Linkage and Key Action (Day Zero) Linked from Action Data
Compliance Monitoring Strategy (CMS)
11. CMS Source Category CMSC
12. CMS Minimum Frequency Indicator CMSI
Note: Generally EPA enters these fields into AFS; state/locals provide this information per
agreement with the EPA Region. An EPA Region may delegate data entry rights to a state/local
agency.
All Regulated Air Program(s) [Note: All applicable air programs should be reflected at the
plant level of AFS.1
13. Air Program APC1
14. Operating Status AST1
15. Subparts for NSPS, NESHAP and MACT SPT1
Note: Any applicable subpart for the NSPS, NESHAP or MACT air program at major and
synthetic minor sources, minor source NESHAP and all other facilities reported as MDR.
Reporting of minor source NSPS and MACT subparts are optional but recommended.
Regulated Pollutant(s) within Air Program(s)
16. Pollutant(s) by Code or Chemical Abstract Service Number PLAP/CAPP
17. Classification(s): EPA/ST ECLP/SCLP
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AFS BUSINESS RULES COMPENDIUM
18. Attainment Status: EPA/ST EATN/SATN
19. Compliance Status: EPA/ST ECAP/SCAP
Actions Within Air Programs (includes Action Number, Type, Date Achieved)
20. Minimum Reportable Actions:
Informal Enforcement Actions: Notice of Violation(s)
Formal Enforcement Actions: Administrative Order(s) and Assessed Penalties, Consent
Decrees and Agreements, Civil and Criminal Referrals, Civil and Criminal Actions
HPV Violation Discovered: Linked actions are FCEs, PCEs, Stack Tests (Observed or
Reviewed), Title V Annual Compliance Certifications, Stack Test Notification Receipt
HPV Addressing Actions: Linked actions include but are not limited to State/EPA Civil
or Criminal Referrals, State/EPA Civil or Criminal Actions, Administrative Orders,
Consent Decrees, Source Returned to Compliance by State/EPA with no Further Action
Required.
FIPV Resolving Actions: Linked actions include but are not limited to Violation
Resolved, Closeout Memo Issued, Source Returned to Compliance by State/EPA with no
Further Action Required.
Full Compliance Evaluations (On or Off Site)
Stack Tests: Pass/Fail/Pending codes (PP/FF/99) are reported in the results code field,
pending codes must be updated within 120 days.
Title V Annual Compliance Certification Due/Received: Reported by EPA unless
otherwise negotiated. The Due Date of a Title V Annual Compliance Certification will
be reported as Date Scheduled on the "Title V Annual Compliance Certification
Due/Received by EPA" action, and is not enforcement sensitive.
Title V Annual Compliance Certification Reviewed: Includes Results Codes for Annual
Compliance Certification reviews: in compliance (MC), in violation (MV) and unknown
(MU). Annual Compliance Certification deviations(s) will be indicated in RD08 for EPA
reviews (and state reviews as negotiated).
Investigations: EPA Investigation Initiated (started) and State/EPA Investigation
Conducted (finished). State Investigation Initiated is added for optional use. EPA and
State Investigation Initiated (started) action types are enforcement sensitive.
Additional Action Information:
21. Results Code RSC1
Note: Pass/Fail/Pending (PP/FF/99) codes are reported for Stack Test actions. Compliance
Results Codes of "In Compliance (MC), In Violation (MV), or Unknown (MU)" are entered for
Title V Annual Compliance Certification reviews.
22. RD08 (Certification Deviations) RD81
Note: EPA reports into AFS unless otherwise negotiated. Compliance Codes of "In Compliance
(MC), In Violation (MV), or Unknown (MU)" are entered for Title V Annual Compliance
Certification reviews.
23. Date Scheduled DTS1
Note: The Due Date of a Title V Annual Compliance Certification will be reported as Date
Scheduled on the "Title V Annual Compliance Certification Due/Received by EPA" action, and
is not enforcement sensitive.
24. HPV Violation Type Code(s) VTP1
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AFS BUSINESS RULES COMPENDIUM
Note: To be identified when the Day Zero action is established.
25. HPV Violating Pollutant(s) VPL1
Note: To be identified when the Day Zero action is established.
Timeliness Standard
26. Action Reported within 60 Days of Event reported in the Date Achieved (DTA1) field of the
action record for state and local agencies, with a minimum upload of six (6) times per year.
Monthly updating is encouraged. Federal Data is to be reported on a monthly basis.
OPTIONAL/DISCRETIONARY DATA REPORTING TO AFS: NON-MDR DATA
The following items cover data that is not considered an MDR, but will be useful and helpful for
program implementation, evaluation and oversight. State and local agencies are encouraged to
report the following items whenever practicable.
Minor Facility information: For minor sources that are not MDR (MDR for minor
facilities is defined as: Minor NESHAP, a minor facility identified within the CMS plan
for evaluation, minor facilities with an enforcement action <3 years old, or any UPV case
regardless of class) reporting is optional but encouraged. Minor source information
would include NSPS and MACT subpart applicability.
Stack Test Pollutant (PLC1)
Partial Compliance Evaluations (PCEs) and specific reporting of On-Site PCE activity
defined as: Complaint Partial Compliance Evaluation, Permit Partial Compliance
Evaluation, Process Partial Compliance Evaluation, Partial Compliance Evaluation On-
Site Observation. (Note: All PCEs are required to be reported by EPA Regional offices.
Also, any negotiated PCEs that are part of an alternative frequency which is part of an
agency's CMS plan are required to be reported.)
Reporting more frequently than every 60 days.
State Investigations initiated (Enforcement Sensitive).
Title V Permit Program Data Elements (PPDEs): Required for reporting to AFS by the
Office of Air Quality Planning and Standards (OAQPS), used by the Office of
Enforcement and Compliance Assurance (OECA) for major source universe population.
To be established when the Title V permit is issued. AFS will require the establishment
of an AFS ID, the individual permit number, category, and event type for permit issued
plus the date achieved. Permit Program Data Elements (PPDEs) include the Permit
Number (ASPN), Permit Category (PMTC), and Permit Issuance Event Types (IF-Permit
Issued and IR-Permit Renewal) and the date (PATY/PDEA).
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AFS BUSINESS RULES COMPENDIUM
SECTION 2: CLEAN AIR ACT STATIONARY SOURCE COMPLIANCE
MONITORING STRATEGY (CMS) POLICY AS IMPLEMENTED IN AFS
A. BACKGROUND:
In April 2001, the Clean Air Act (CAA) Stationary Source Compliance Monitoring
Strategy (CMS) was revised to provide national consistency in developing stationary source air
compliance monitoring programs. The CMS provides a framework for developing stationary
source air compliance monitoring programs that focus on achieving measurable environmental
results. State, Locals, and Regions record their compliance monitoring activities and enter
facility-specific compliance data in AFS.
The CMS introduces new compliance monitoring tools: Full Compliance Evaluations,
Partial Compliance Evaluations, and Investigations. A Full Compliance Evaluation (FCE) is a
comprehensive evaluation of the compliance status of a facility. It addresses all regulated
pollutants at all regulated emission units. Furthermore, it addresses the current compliance status
of each emission unit, as well as the facility's continuing ability to maintain compliance at each
emission unit. A Partial Compliance Evaluation (PCE) is a documented compliance assessment
focusing on a subset of regulated pollutants, regulatory requirements, or emission units at a given
facility. A PCE should be more comprehensive than a cursory review of individual reports. It
may be conducted solely for the purpose of evaluating a specific aspect of a facility, or combined
over the course of a year to satisfy the requirements of a Full Compliance Evaluation. PCEs may
include: Site Visits, Conferences, Review of Required Reports, Compliance Reviews of
individual Air Programs, Emission Inventory reviews, Stack Test reviews, or other activities. It
is recommended that Regional values of PCEs describe the evaluating action taking place,
such as "Conference on Site" or "RATA Review". An Investigation is limited to a portion of
a facility, is more resource intensive, and involves a more in-depth assessment of a particular
issue. It usually is based on information discovered during a Full Compliance Evaluation, or as
the result of a targeted industry, regulatory, or statutory initiative. Also, an Investigation often
requires the use and analysis of information not available in EPA data systems. It is best used
when addressing issues that are difficult to evaluate during a routine FCE because of time
constraints, the type of preliminary field work required, and/or the level of analytical expertise
needed to determine compliance.
Additionally, stack testing is an important tool used to determine a facility's compliance
with emission limits established pursuant to the CAA. CMS recognized that consistent,
complete and accurate stack test information is critical in managing a national air program.
Hence, the CMS recommends that States/Locals should conduct a stack test, or require the
facility to conduct a stack test, whenever they deem appropriate. States/Locals should also
conduct a stack test, or require the facility to conduct a stack test, when there are no other means
for determining compliance with the emission limits. The data and results (Pass/Fail) of all stack
tests should be entered in AFS, and the High Priority Violation (HPV) status adjusted as
appropriate.
The policy focuses on Title V major and larger synthetic minor sources. These sources
are marked in AFS with a CMS Category:
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CMS CATEGORIES (CMSC)
CMSC
A
E
M
G
S
N
O
Z
DESCRIPTION
STATE/LOCAL AGENCY OVERSIGHT AT MAJOR SOURCES
EPA OVERSIGHT FOR TRIBAL LANDS AT MAJOR SOURCES
STATE/LOCAL AGENCY OVERSIGHT AT MEGA SOURCES
EPA OVERSIGHT FOR TRIBAL LANDS AT MEGA SOURCES
STATE/LOCAL AGENCY OVERSIGHT AT 80% SYNTHETIC MINOR SOURCES
EPA OVERSIGHT FOR TRIBAL LANDS AT 80% SYNTHETIC MINOR
SOURCES
STATE/LOCAL AGENCY OVERSIGHT AT OTHER/ALTERATIVE SOURCES
EPA OVERSIGHT FOR TRIBAL LANDS AT OTHER/ALTERATIVE SOURCES
Since the inception of the policy, an additional category has been introduced: O=Other.
This category allows States and Regions the ability to include minor or other than 80% Synthetic
Minor sources into the plan, as negotiated alternatives for sources that are not being evaluated
within the negotiated time frame as agreed upon with the Regional office. In order to accurately
track and document evaluations of sources on tribal lands, additional values have been added to
the CMS table in 2008.
Along with a CMS category, each source in the plan has a recommended evaluation
frequency. The default values for each category are:
A/E Major Sources: Evaluation every 2 Years
M/G Mega Sources: Evaluation every 3 Years
S/N 80% Synthetic Minor Sources: Evaluation every 5 Years
O/Z Other Sources: No default value
The CMS policy was placed into effect during FY2002. The first two years of the policy
are FY2002 - FY2003. Major sources identified in the plan should have received a Full
Compliance Evaluation during this period. AFS can provide detailed listings of sources that
have been identified as belonging to the CMS universe, along with dates of last evaluation.
B. PLAN IMPLEMENTATION AND AUTOMATIC UNKNOWN COMPLIANCE
STATUS:
CMS plans are renewed every two years, with updating allowed on an annual basis. The
CMS policy also includes tracking of stack test observations, and reviews completed by Regional
and State staff. Previous monitoring policies did not credit in-house reviews of stack tests. Also
included are the reviews of Annual Compliance Certifications from Title V sources. These new
reviews are also reported to AFS and include deviations reported and reported compliance.
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Another feature of the plan is the ability to use AFS to generate an unknown compliance
status for any CMS source that has not received a Full Compliance Evaluation within the
negotiated frequency. The automatic unknown compliance status generation utility will generate
a "U" value to the EPA Compliance Status fields. AFS will use the date of last inspection or
evaluation, compare it to the current date and then if no evaluation has been completed during
the frequency period, automatically generate an unknown compliance status value of "U". AFS
will maintain the generated status on the SIP or FESOP air program code, using the pollutant
"FACIL".
The original utility in AFS utilized the CMS Category (CMSC) and the supplied
Evaluation Frequency (CMSI) and the date of the last evaluation to generate an unknown
compliance status. Also included in the algorithm was the ability to identify plants that had been
recently added to AFS or had a change in their CMS category, in order to correctly generate the
status. A value of "U" for "Unknown Compliance Status" was generated in the EPA
Compliance Status values for plants that have not been evaluated within their indicated
frequency, based on a 'rolling window' of time. For example, a major source with the default
evaluation period was defined with a CMSC of 'A' and a CMSI of '2'. Unknown compliance at
this plant would be generated after 730 days from its last evaluation. The utility used to generate
the unknown value runs in two parts: Generation and Un-generation of the unknown value.
The application of the Unknown Compliance Status on a rolling-day window required
that the subsequent evaluations had to be held before the next scheduled evaluation otherwise the
unknown value would be applied. For example, if a source was evaluated on October 1, 2002,
then it would need to be evaluated on or before October 1, 2004 in order to avoid the unknown
value. State and Local Agencies requested a review of the utility in order to provide more
flexibility in the scheduling of subsequent evaluations.
The utility was changed on October 1, 2005. The new utility does not generate the
Unknown Compliance Status until the end of a fiscal year in which the plant is scheduled for
evaluation. For example, a plant evaluated in January 2003 has a CMSC of "A" and a CMSI
(frequency) of 2. The previous utility would use a rolling window of time for the generation of
the unknown status, and would generate it in January 2005 if no Full Compliance Evaluation
activity has been entered into AFS. Now, state/local agencies will have until the end of FY2005
(September 30, 2005) to evaluate the plant. This provides the State/Local Agency with the
flexibility to use the remainder of the fiscal year in which to evaluate the plant.
Additionally, the generation of Unknown Compliance Status in the new utility will
not be run until December of each year in order to provide a 60-day lag of application, in
accordance with the requirements of the recently-renewed Information Collection Request (ICR).
During the months of October and November of 2005 the generation of the value will not be run.
The un-generation of the unknown value, however, will continue to run monthly.
Appendix 9, AFS Utilities in 2009, provides a schedule of when the system will be
updated with automatic Unknown Compliance Status generation. The charts in Appendix 1
show how the utility will be executed in AFS, additionally; the table below indicates the
differences between the utilities.
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Utility Features
Old Utility
New Utility
Uses CMSC, CMSI, Default Date of
the Latest FCE, CMS Start Date and
the current default Compliance
Status to generate unknown
compliance.
Same
Same
Sources already in noncompliance
or unknown compliance are not
affected
Same
Same
Air Program
Utility used existing air programs,
starting with SIP and working
downward until an existing air
program code was utilized.
Utility will use either the Title V or
SIP air program. If Title V is
present, it will be used. If not, SIP
will be used. If SIP is not present,
the utility will generate the SIP air
program.
Air Program Pollutant
The unknown value of "U" is
generated on the FACIL air program
pollutant. If this pollutant is not
already present on the plant records,
it is generated.
Same as the old utility.
Frequency of Utility
The Generation and Un-generation
of the value was originally run each
night. Due to Working Capital Fund
restrictions, the frequency of the
utility was recently changed to a
monthly basis.
The generation utility will be run
once a month, during the first
Thursday of the month, with the
exceptions of October and
November of each year. This
ensures that the values are correctly
generated before the OTIS/ECHO
extracts from AFS are completed
during the second weekend of each
month, and before AFS generates
monthly historic compliance status
values. At the start of each fiscal
year, the generation will be
delayed for 60 days (not run
during October and November);
however, the un-generation will
continue on a monthly basis.
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A C's of Generating an Unknown Compliance Status
A = Actual (FY of the latest Actual FCE)
= Baseline (FY of the Current date - CMSI)
C = Current (FY of the Current Date)
If is greater than A, then generate unknown compliance
Apply the formula above to these examples to see how the utility will generate Unknown
Compliance Status:
Example
1
2
3
4
5
6
Dates of Latest FCE for major sources with
a CMSC of A and a CMSI of 2:
February 12, 2004
July 16, 2005
September 5, 2004
October 31 , 2004
December 1, 2004
July 16, 2003
With no FCE reported,
Unknown Compliance will
generate on:
December 1, 2006
December 1, 2007
December 1, 2006
December 1, 2007
December 1, 2007
December 1, 2005
Explanation of Example 1 -
A = FY04 (February 12, 2004)
= FY05 (October 1, 2006 (FY07) - 2)
C = FY07 (October 1, 2006)
If (FY05) is greater than A (FY04), then generate unknown compliance
Explanation of Example 2 -
A = FY05(July 16, 2005)
= FY06 (October 1, 2007 (FY08) - 2)
C = FY08 (October 1, 2007)
If (FY06) is greater than A (FY05), then generate unknown compliance
Explanation of Example 3 -
A = FY04 (September 5, 2004)
= FY05 (October 1, 2006 (FY07) - 2)
C = FY07 (October 1, 2006)
If (FY05) is greater than A (FY04), then generate unknown compliance
Explanation of Example 4 -
A = FY05 (October 31, 2004)
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= FY06 (October 1, 2007 (FY08) - 2)
C = FY08 (October 1, 2007)
If (FY06) is greater than A (FY05), then generate unknown compliance
Explanation of Example 5 -
A = FY05 (December 1, 2004)
= FY06 (October 1, 2007 (FY08) - 2)
C = FY08 (October 1, 2007)
If (FY06) is greater than A (FY05), then generate unknown compliance
Explanation of Example 6 -
A = FY03(July16, 2003)
= FY04 (October 1, 2005 (FY06) - 2)
C = FY06 (October 1, 2005)
If (FY04) is greater than A (FY03), then generate unknown compliance
Appendix 1 contains a chart that shows further information on the automated utility process.
See Section 3C-Action Records for specific requirements for each CMS policy data
element. For further information on the CMS policy and implementation in AFS, refer to:
http://www.epa.gov/compliance/resources/publications/data/systems/air/cmstechman.pdf
C. TRACKING CMS PLANS WITH AFS FIXED REPORTS:
Two useful reports have been added to AFS to facilitate tracking of CMS plan
completion: AFS 655-CMS Summary and AFS 670-Illogical CMS Assignments.
The AFS 655 Report highlights each source within the CMS plan (identified by CMS category)
and, depending upon the date of the report execution, determines if the source has been evaluated
within the negotiated frequency identified in the CMSI field. This report is available as a printed
report or workfile. It is recommended that the report be run as a workfile for data manipulation.
The AFS 670 Report targets sources with illogical CMS category assignments. For example, if a
minor source has been identified with CMSC of S (identifying it as an S-80% Synthetic Minor
source), the source will be presented in the report's output. Any major source not included in the
CMS plan (default classification is A and CMSC is blank) is also included in the output of the
report. This report is available as a printed report or workfile. It is recommended that the report
be run as a workfile for data manipulation.
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D. HISTORIC CMS RECORDS:
During FY2008 the system was asked if historic values of the CMSC could be
maintained within AFS. State Review Framework (SRF) reviews of prior fiscal years are using
current CMSC and CMSI values that in many cases have been changed since the timeframe of
review. Programming is underway to create historic records of the CMSC and CMSI in AFS and
is expected to be completed by FY2010.
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SECTION 3: USING AFS FOR COMPLIANCE/ENFORCEMENT TRACKING
A. PLANT LEVEL RECORDS
AFS maintains a Plant General record which includes all source geographical information such
as Plant Name, Street Address, City, County Name, State, Government Facility Code and Zip
Code. Along with this information are optional data reporting features for mailing address, staff
assigned to track the source, contact names and telephone numbers, and other miscellaneous
information. This section of the compendium will document information about data on the Plant
General Records. See Appendix 2 for a list and description of the fields in the AFS structure.
1. Entering a New Plant and Identification Numbers into the Database:
The FIP State and County code plus a five-digit PCDS number are required to enter a new plant
in AFS. Numbering conventions for the PCDS number are at the discretion of the delegated
agency. There should be only one plant ID for each source. A plant is defined as an entity
operating at a physical location contained within a fence line. Change of ownership does not
affect a source number; history of the source goes to the new owner. A plant identification
number should change if the facility changes physical location. A change in location not only
requires a new identification number, but requires all historic information to be reestablished
under the new number. It is recommended that when a new major source is established in AFS,
the AFS Plant ID number (for Title V Operating Permit Data) also be established.
On June 30, 2004 the AFS Configuration Control Board approved the following procedure for
plants that may relocate:
WITHIN THE SAME STATE, SAME COUNTY: A change of Street Address (STRT) is required.
Optional records via a comment or action (Address Change) may be entered into AFS to
document the address change (this optional information is strongly encouraged).
WITHIN THE SAME STATE, DIFFERENT COUNTY: A new SCSC is required. The Source
Swap utility is available to facilitate changing the plant ID. Contact the AFS Helpline for
assistance in maintaining Compliance History records.
LOCATION CHANGE TO A DIFFERENT STATE: Data changes for plants relocating to
different states should be handled on a plant-by-plant basis, as different legal situations will
apply. Should the relocation cross EPA Regional boundaries, the appropriate AFS Compliance
Manager should be contacted for instructions on assigning ID numbers.
2. Plant Name:
AFS has a 40-character field for Plant Name. The current plant name is to be recorded in this
field, taken from a plant permit or other documents commonly used such as invoices, signs,
telephone listings or other business documents. Many agencies use the name cited on the Title V
permit for the Plant Name. The name should identify the owning corporation and site name, if
applicable. Name changes should be entered as soon as they are identified to the delegated
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agency. Many agencies document a name change in the plant comments and/or Regional
actions.
3. Latitude/Longitude:
Data in latitude/longitude fields in AFS is considered obsolete. It was owned and maintained by
the Air Emission Inventory community which no longer uses AFS as its repository of data.
4. SIC/NAIC Codes
AFS will accept either Standard Industrial Code (SIC) or the North American Industrial Code
(NAIC) codes; however, it is recommended that BOTH codes be populated. During FY2008,
efforts have been made to populate NAICS fields for those SICs with one-to-one definitions in
order to increase the number of sources with populated NAICS codes. The primary SIC/NAICS
code should reflect the major activity at the plant. A new ad hoc acronym called SCNC has been
created and will function like an "OR" operator between SIC and NAICS code searches in ad
hoc retrievals. This new search acronym can be used to search for plants that have a SIC or
NAICS code that matches the specified value given by the user in any ad hoc retrieval. It
compares the User-specified value with the primary SIC code and the NAICS code on the Plant-
General record. If the SCNC value is 4 digits long, it will be compared against the plant's SIC
code. If the SCNC value is 6 digits long, it will be compared against the plant's NAICS code.
SCNC values of lengths other than 4 or 6 will return nothing as these codes do not exist in AFS.
5. State Registration Number:
Although this is an optional reporting field, it is encouraged that agencies populate their own
system number in AFS for reference. This field can be used to facilitate reconciliation of state
systems to AFS.
6. Governmental Facility Code:
This field identifies sources owned or operated by different levels of government. Although
identification of the owner/operator can be defined down to the municipal level, at a minimum
any federally owned/operated source needs to be defined.
7. Portable Sources:
The County Code of "777" is to be used for reporting portable sources to AFS. A portable
source is defined as a process that may or may not be permitted but can be moved from place to
place, for example, an Asphalt Processing Plant is movable from site to site and can emit
pollutants above the major threshold level. The Facility Registry System (FRS) and
ENVTROFACTS web site will map and present sources with a "777" county number as located
at the center of the county identified by the Plant City Name.
8. Archiving Permanently Closed Sources:
The Operating Status of Permanently Closed is used when the source owner/operator has no
future legal right to reopen the source without full review by the permitting authority, i.e. where
the owner/operator has relinquished all permits to the permitting authority. Permanently Closed
sources may be archived from the production mode of AFS after six years of no activity IF the
following situations are true:
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The source has never had a high priority (HPV) or significant violation (SV);
Has never been part of a CMS plan;
Has never had formal enforcement activity; or
Has never had a change to compliance status history.
Sources that have had these situations must not be archived. It is requested that these sources not
be removed from the production mode of the database unless the data is incorrect. HPV/SV data
as well as evaluation plans are used in many different types of data analyses. Compliance
history information is used in trend analyses. It is recommended that state and local users of
AFS contact their Regional AFS Compliance Manager before archiving sources, as some regions
have instituted procedures for class change, deletion of plants, and archiving. Regional
managers may require additional archiving procedures, but regional requirements should be as
stringent as this guidance.
9. Local Control Region (LCON):
The Local Control Region is a user defined two-character code identifying the local control
region with jurisdiction over a plant. It is an optional field, and can be used to identify a facility
to which a Region, State or Local Agency may have jurisdiction. Use of the LCON field can
quickly facilitate oversight of sources within an agency were jurisdiction crosses county or city
lines, but not state lines.
An ad hoc retrieval from AFS using county code(s) in the selection criteria may result in more
facilities than needed. However, if LCON = xx is used as selection criteria, then only those
facilities within the LCON will be presented in the report. LCON selection criteria are also
available in OTIS and ECHO as options for retrieving data.
When used in update, LCON values will be validated against the LCON table. The LCON table
will be located as an entry on the Utility Table menu and it has the same functions as other tables
in AFS. LCON values can be globally entered for all plants in a geographic area. Use batch
transaction type 10-3 for the specific geographic area, and include the following information:
SCSC columns 1-10
Transaction type column 11-12; Value '10'
Sequence codecolumn 13; Value '3'
LCON columns 67-68
Update code column 80; Value 'C'
In June 2006, the listing of LCON values in the AFS were updated (please see Appendix 4 for
the listing of LCON values as of March 2009).
B. AIR PROGRAM AND AIR PROGRAM POLLUTANT RECORDS
1. Air Programs:
An Air Program code in AFS defines a regulatory program of the Clean Air Act applicable to a
facility. All applicable air program codes are to be reported. In cases where State or Local
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delegations incorporate stricter requirements than the federal regulatory program, reporting of
the federal air program is sufficient. A plant must have at least one applicable air program with
one air program pollutant in order to be established in AFS. Air program codes are also
necessary for reporting actions in AFS, and must be established on Screens 302/303 (Air
Program Update and Air Program Pollutant Update) before use in an action record. Permits
issued to a source will document the applicable air programs and can be used as a source of data
for this field.
a Air Program Operating Status:
An operating status must be reported for each air program. The Operating Status
represents the operational condition of a plant associated with a given air program. The
most significant value will bubble up to the Plant General Record. The value of most
significant operative value to least is: O=Operating, L=Landfill, R=NESHAP
Renovation, D=NESHAP Demolition, S=NESHAP Spraying, I=Seasonal,
T=Temporarily Closed, C=Under Construction, P=Planned Facility, X=Permanently
Closed. Statuses O, T, and I are used in the National RECAP reporting measures. Values
L=Landfill, R-NESHAP Renovation, and D=NESHAP Demolition and S=NESHAP
Spraying are considered obsolete.
b. Applicable Air Program Codes:
0 State Implementation Plan (SIP)
1 SIP Source under Federal Jurisdiction
3 Non-Federally Reportable Source
4 Chlorofluorocarbons (CFC) Tracking
6 Prevention of Significant Deterioration (PSD)
7 New Source Review (NSR)
8 National Emission Standards for Hazardous Air Pollutants (NESHAP)
9 New Source Performance Standards (NSPS)
A Acid Precipitation
F Federally Enforceable State Operating Permit - Non Title V (FESOP)
I Native American
M Maximum Achievable Control Technology (MACT) Section 63 NESHAP
T Tribal Implementation Plan (TIP)
V Title V Permits
Air program code definitions continue:
Code Description
0 State Implementation Plan (SIP)
Section 110 of the Clean Air Act requires each state to adopt and submit to EPA for
approval a SIP that provides for the maintenance, implementation and enforcement of the
National Ambient Air Quality Standards (NAAQS). Each SIP must include a permit
program to regulate the modification and construction of any stationary source of air
pollution, including stationary sources in attainment and nonattainment areas of the state,
as necessary to assure that NAAQS are achieved. SIP requirements are federally
enforceable under Section 113 of the Act. Reference 40 CFR Part 52. The SIP air
program is considered applicable to each Federally Reportable stationary source in AFS.
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Additional reporting requirements for SIP are promulgated as standards for various
industrial categories. These standards are reported as subparts to the SIP, and are
generally identified using the same subpart identification as the New Source Performance
Standards (NSPS). Reporting of SIP subparts are optional, see Air Program Code 9, New
Source Performance Standards (NSPS) for a list of applicable subparts.
1 SIP Source under Federal Jurisdiction (FIP)
Under current law, a federally implemented plan to achieve attainment of air quality
standards is used when a state is unable to develop an adequate plan, or if jurisdiction
does not exist. Sources located on Indian Land should reflect the Native American air
program code.
3 Non-Federally Reportable
Used to report State/Local/Tribal requirements not defined as federally reportable
[reference Section 1, Minimum Data Requirements (MDRs)].
4 Chlorofluorocarbons (CFC) Tracking
Under Title VI of the Clean Air Act, EPA is responsible for several programs that protect
the stratospheric ozone layer. These programs include: Motor Vehicle Air Conditioning;
Stationary Refrigeration and Air Conditioning, Halon Blends and Handling; Phase-out of
Ozone Depleting Substances; Methyl Bromide; Nonessential Products Ban; Product
Labeling, and Federal Procurement. Reference 40 CFR Part 82. This program is not
delegated to State, Local, or Tribal agencies. Evaluations completed at a source with
only the CFC air program should be reported as an FCE, evaluations completed at
sources with multiple air programs should be reported as PCEs.
6 Prevention of Significant Deterioration (PSD)
Part C of the Clean Air Act sets requirements for the prevention of significant
deterioration (PSD) of air quality in those areas designated as either attainment or
unclassifiable for purpose of meeting the National Ambient Air Quality (NAAQS)
standards. These requirements are designed to protect public health and welfare, to
assure that economic growth will occur in a manner consistent with the preservation of
existing clean air resources and to assure that any decision to permit increased air
pollution is made only after careful evaluation of all the consequences of such a decision
and after public participation in the decision making process. PSD prohibits the
construction and operation of a major emitting facility in an area designed as attainment
or unclassifiable unless a permit has been issued that compiles with Section 165 of the
Act, including the requirement that the facility install the best available control
technology for each pollutant subject to regulation.
7 New Source Review (NSR)
New Source Review is a preconstruction permitting program that serves two important
purposes:
a. It ensures the maintenance of air quality standards when factories, industrial boilers
and power plants are modified or added. In areas with unhealthy air, NSR assures that
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new emissions do not slow progress toward cleaner air. In areas with clean air, especially
pristine areas like national parks, NSR assures that new emissions fall within air quality
standards. Emission calculations are completed using potential emissions.
b. The NSR program assures that state of the art control technology is installed at new
plants or at existing plants that are undergoing a major modification.
In August 2003, EPA issued a final rule that creates a category of activities that
automatically will be considered routine maintenance, repair and replacement (RMRR)
under the NSR permitting program. The rule defines a process unit, delineates the
boundary of a process unit, defines a "functionally equivalent" component, and defines
basic design parameters for electric utility steam generating units and other types of
process units. See http://www.epa.gov/ttn/nsr/rule_dev.html for a copy of this rule.
National Emission Standards for Hazardous Air Pollutants (NESHAP PART 61)
Section 112 of the Clean Air Act identifies substances that have been designated as
hazardous air pollutants (HAPs), known for serious health effects, including cancer, from
ambient air exposure. HAPs include: Asbestos, benzene, beryllium, coke oven
emissions, inorganic arsenic, mercury, radio nuclides and vinyl chloride. Reference 40
CFR Part 61. Additional reporting requirements for NESHAP are promulgated as
standards for various industrial categories. These standards are identified as subparts to
the NESHAP, and can be reported to AFS in the 302/502 (Air Program) screen. Subpart
reporting is mandatory. For a complete listing for the codes for 40 CFR Part 61
(NONMACT NESHAP) Subpart please refer to Appendix 5: NSPS, NESHAP and
MACT Air Subpart Tables.
New Source Performance Standards (NSPS PART 60)
Section 111 of the Clean Air Act requires EPA to publish a list of categories of stationary
sources that emit or may emit any air pollutant, and to establish federal standards of
performance for new sources of air pollutants. The list must include categories of
sources which are determined to cause or significantly contribute to air pollution which
may endanger public health or welfare. "New sources" are defined as stationary sources,
the construction or modification of which is commenced after the publication of the
regulations or proposed regulations prescribing a standard of performance applicable to
such source. Reference 40 CFR Part 60. Additional reporting requirements for NSPS are
promulgated as standards for various industrial categories. These standards are reported
as subparts to the NSPS and also to the SIP. Reporting of NSPS subparts is mandatory.
As all subpart identifiers are added to AFS as upper-case letters, a conflict with certain
subparts using upper and lower case letters has required a special character use for proper
identification of the subpart. Two NSPS subparts have been identified with conflicting
upper and lower case letters. The AFS Control Configuration Board (CCB) approved the
following data entry procedure on June 30, 2004 for use in uniquely identify the
following subparts:
AA/A will report AAA: Standards of Performance for Steel Plants: Electric Arc
Furnaces and Argon-Oxygen Decarburization Vessels Constructed after August 7, 1983
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AAA will continue to report AAA: New Residential Wood Heaters
C/C will report Cc: Municipal Solid Waste Landfills
CC will continue to report CC: Standards of Performance for Glass Manufacturing
Plants
The use of the "/" character before a lower case letter will provide unique
identification of the subpart within AFS.
For a complete listing of codes for 40 CFR Part 60 (NSPS/SIP) Subparts please refer to
Appendix 5: NSPS, NESHAP and MACT Air Subpart Tables.
A Acid Precipitation
The Acid Rain Program requires major reductions of sulfur dioxide and nitrogen oxide
emissions (key components of acid rain) from electric utilities, while establishing a new
approach to environmental protection through the use of market incentives, a "cap and
trade" process. Affected sources are required to install systems that continuously monitor
emissions in order to track progress, ensure compliance, and provide credibility to the
trading component of the program. Regulated sources must report all emissions as
measured by continuous emissions monitors. EPA has established standard reporting
procedures and has issued standard software for such reporting. Emissions are submitted
to the Emissions Tracking System (ETS) using ETS-FTP software. Although AFS users
are encouraged to identify and track CFC tracking sources, the tracking of this program is
done in the ETS-FTP software. See
http://www.epa.gov/airmarkt/reporting/edr21/index.html for more information on
reporting Acid Rain emissions.
F Federally Enforceable State Operating Permit Program (FESOP)
This program (usually through SIP revision) provides a mechanism for states to establish
federally enforceable State operating permits limiting the potential to emit for sources to
remain below the applicability threshold for the operating permits program of Title V of
the Clean Air Act (CAA). This program is available to allow States to issue FESOPs to
small sources and exempt them from the Title V review, as the large number of small
sources could be a resource burden on both the agency and the small sources. FESOP
provides the mechanism to establish federally enforceable limits on sources' potential to
emit below the Title V threshold. This air program is used for reporting sources
classified as Synthetic Minor (SM).
I Native American
This program is used to identify sources located on Indian Lands. Sources do not have to
be operated by tribal entities, but are subject to Tribal authority. In the absence of a
Tribal Authorization Rule (TAR) or Implementation Plan (TIP), this air program will be
used to identify any source subject to Tribal rule. All other applicable air programs need
to be identified.
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M Maximum Achievable Control Technology (MACT PART 63)
The EPA is directed to use technology-based and performance-based standards to
significantly reduce routine emissions of hazardous air pollutants of facilities within an
industry group or source category. The NESHAP standards implemented in 1990
regulate specific categories of stationary sources. The standards of this part are
independent of NESHAP. A MACT standard is based on emission levels that are already
being achieved by the lower-emitting sources of an industrial sector. Eight years after a
MACT standard is issued, EPA must assess the remaining health risks in the categories
and may implement additional standards to care for any remaining risk. Reference 40
CFR Part 63. See http://www.epa.gov/ttn/atw/socatlst/socatpg.html for a listing of all
source categories and promulgation schedules. Please refer to Appendix 5: NSPS,
NESHAP and MACT Air Subpart Tables for a complete listing of the codes for 40 CFR
Part 63 (MACT NESHAP) Subparts as of June 2006.
T Tribal Implementation Plan (TIP)
A TIP is an enforceable plan approved by the EPA that provides for the maintenance,
implementation and enforcement of the National Ambient Air Quality Standards
(NAAQS). It contains strategies for maintaining and improving current air quality, attain
NAAQS if in violation, provides for a preconstruction permitting program for new and
modified major sources or minor sources, and a plan to handle regional haze. It does not
include Acid Rain (Title IV), Operating Permits (Title V), or Stratospheric Ozone
Protection (Title VI) programs. TIPS are authorized by Section 301(d) of the CAA and
through the Tribal Authority Rule (TAR) of 1998. TIP requirements are federally
enforceable under Section 113 of the Act. All applicable air programs need to be listed
along with this air program. Air program code "I" can be discontinued upon effective
date of the TIP.
V Title V Operating Permits
Reference 40 CFR Part 70. The Final Rule (July 31, 1992) established an operating
permit program for States to develop programs for issuing operating permits to all major
stationary sources and to certain other sources. Title V does not impose new
requirements; it does provide a permit to operate that assures compliance with all
applicable requirements. It allows the delegated agency the authority to collect
permitting fees. All permits are required to contain standard permit requirements that
specify and reference the origin of authority for each applicable term or condition, the
duration of the permit (not to exceed 5 years), the monitoring and related recordkeeping
and reporting requirements, emissions trading allowed, Federally-enforceable and
compliance requirements. Any operating source with Title V permit application pending
should have the "V" air program code with the operating status of "P" for pending
entered in AFS. Once the permit has been issued, the operating status should be
upgraded to "O" for operating.
c. Air Program Subparts:
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Air program subparts are additional reporting requirements promulgated as standards for
various industrial categories. Reporting of subparts for NSPS, NESHAP and MACT are
required. AFS will provide a screen for reporting subparts on the following air programs:
0 State Implementation Plan (SIP)
1 SIP Source under Federal Jurisdiction
8 NESHAP
9 NSPS
M MACT
AFS was recently upgraded to allow up to 12 subparts to be added to an air program.
(December 2005). See Appendix 5, NSPS, NESHAP and MACT Air Subpart Tables.
2. Air Program Pollutant Records:
a. Pollutant Code or Chemical Abstract Number:
Each source in AFS requires at least one air program code and at least one
pollutant. Pollutants are reportable using either a five-digit pollutant code or a
Chemical Abstract Service Number (CASN). AFS has tables listing all pollutant
codes and CASNs. If the Pollutant Code is used and an equivalent CASN exists
for the code, AFS will populate the CASN automatically. If the CASN is entered
and an equivalent Pollutant Code exists, AFS will populate the Pollutant Code
automatically.
b. Classification:
AFS requires the user to report a category identifying the potential amount of
pollutants emitted per year. Criteria pollutant (CO, SO2, VOC, Pb, NO2,
Particular Matter) classification uses an emissions threshold identified by EPA
establishing major thresholds based on attainment with National Ambient Air
Quality Standards (NAAQS). Major emission thresholds are 100 tons or more per
year in an area that is currently in attainment. Attainment/Nonattainment
designations can be found at http://www.epa.gov/oar/oaqps/greenbk/ . EPA has
the ability to document a classification value separate from the state/local value.
Nonattainment designations will decrease the emissions thresholds:
,, . . Nonattainment Threshold (Tons per
Pollutant . .,, . \
Classification Year)
Ozone Marginal 100
Ozone Moderate 100
Ozone Serious 50
Ozone Severe 25
Ozone Extreme 10
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_. ,, ^ ^ Nonattamment Threshold (Tons per
Pollutant . .,, . \
Classification Year)
CO Moderate 100
CO Serious 50
PM-10 Moderate 100
PM-10 Serious 70
Emission thresholds for Hazardous Air Pollutants (HAPs) are sources with the
potential to emit (controlled or uncontrolled) 10 tons of any one HAP, or 25 tons
of any combination of HAPs (reference Section 112(a)). Source Classification
values are:
A Major emissions; Actual or potential emissions are above the applicable
major source thresholds
SM Synthetic Minor emissions; Potential emissions are below all applicable
major source thresholds if an only if the sources complies with Federally
enforceable regulations or limitations (Potential to emit at the major
threshold but due to operation restrictions or other controls emit at the
minor level)
B Minor emission; Potential uncontrolled emissions are below the applicable
major source thresholds
C Emissions classification is unknown
The values A, SM, B, and C are considered the valid values for this field and
should be used for Air Program Pollutant data entry using Update Screen 303,
Browse Screen 503, and Batch Transaction 131 - columns 25 - 26. .
As of October 1, 2006, AFS classification codes of Al, A2, El, ND, and UK
will be coded as obsolete and consequently are no longer available for data
entry. This action was taken to simplify data entry and description of
classifications.
AFS will bubble up the highest classification value from the air program records
to the Plant General records (DCL1-Default Class, ECL1-EPA Class, and SCL1-
State Class). Plant level compliance status and classification are automatically
generated in AFS using the Air Program and Air Program pollutant records for
the plant. No exclusion was provided for permanently closed air program
resulting in plant level classification and compliance status values generated from
shut down air programs. In order to prevent bubble up values from air programs
with a 'Permanently Closed' operating status, AFS will exclude operating status
values from permanently closed facilities unless there is only one air program at
the plant.
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For example: A facility has multiple air programs. The SIP Air Program is
operating and is classified as SM. The Title V Air Program is permanently closed
(status X) and its associated pollutants are shut down (Compliance Status 9) but
the pollutants recorded for the Title V Air Program reference a major
classification. The classification values for the Title V pollutants are more
significant than the SIP, the major classification bubbles up to the plant level
indicating it to be a major facility even though the Title V Air Program is shut
down. The desired value in this instance should be the SM classification.
To address this, if the Air Program Status for an air program is permanently
closed (AST1=X), then it is excluded from the bubble up of plant level
classification and compliance status. However, if a plant only has permanently
closed air programs, then compliance and classification would be generated using
the existing air program(s) even though they're permanently shut down.
Additionally, if the Compliance Monitoring Strategy Category (CMSC) is
present, all air programs are included in the bubble-up of plant level classification
and compliance status regardless of operating status.
c. Compliance Status:
Each pollutant must have a corresponding compliance status. Compliance is
defined within 4 categories: In Violation, In Compliance, Meeting Schedule, and
Unknown Compliance. EPA has the ability to record a compliance status in
addition to the state/local compliance value.
The following definition of compliance with the Clean Air Act is extracted from
The Timely and Appropriate (T&A) Enforcement Response to High Priority
Violations (HPVs), June 1999:
"/ซ Compliance means all Federal and State administrative and judicial action
against the source is complete and the source has been confirmed to be complying
with the CAA. This term, as it is used in the HPVPolicy, refers to a source being
in compliance with all aspects of CAA requirements, not simply their emission
limit:'
A source with pending enforcement activity is considered in violation or meeting
a schedule until all penalties are completely paid, all injunctive relief,
supplemental enforcement actions, civil and judicial activity are completed.
Unaddressed High Priority Violators must be listed in violation until addressed:
status is then changed to Meeting Schedule or a violation status as appropriate
until resolution. Valid values for compliance status are listed in order of worst
case scenario to best, suggested use is highlighted in bold:
VIOLATION
B In violation with regard to both emissions and procedural compliance
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1 In Violation - No schedule
6 In violation - Not meeting schedule
7 In Violation - Unknown with regard to schedule*
W In violation with regard to procedural compliance
UNKNOWN COMPLIANCE
Y Unknown with regard to both emissions and procedural compliance
0 Unknown compliance status
A Unknown with regard to procedural compliance
U Unknown by Evaluation Calculation (Generated value - not available for
input)
MEETING SCHEDULE
5 Meeting Compliance Schedule
IN COMPLIANCE
C In compliance with procedural requirements
4 In Compliance - Certification (Used in reporting Title V Annual
Compliance Certifications)
3 In Compliance - Inspection (Used in reporting compliance
determinations from Full Compliance Evaluations)
M In Compliance - CEMS
2 In Compliance - Source Test
8 No Applicable State Regulation
9 In Compliance - Shut Down
P Present, See other programs (This compliance status is a place holder
used to avoid assigning a state compliance status when the state has not
supplied a value.)
*In January 2009, status 7 was moved from an UNKNOWN classification to
the VIOLATION classification, as voted by the AFS Compliance Managers.
d. Attainment/Nonattainment Indicator:
Criteria pollutants (VOC, SO2, NO2, Pb, Particular Matter, CO) have attainment
designations that need to be recorded in AFS. These indicators are not
automatically generated and must be supplied by the user. Reference the EPA
Green Book (http://www.epa.gov/oar/oaqps/greenbk/) for the most recent
designation values. EPA has a value available separately from the state value. It
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is anticipated that the EPA values will be updated twice yearly with the expected
months of update being March and September of each calendar year. After an
update has been completed users should notice the pollutant record will reflect the
date updated and JH1 (System Administration) as the User ID responsible for
making the update. States and Local Agencies may request blanket population of
the State values (counties with partial designations will not be populated) by
contacting their Regional AFS Compliance Manager.
C. ACTION RECORDS
1. Fields:
These activities are reported to AFS via an Action Record (Screen 306 for update/Screen 507 for
browse) and contain the following components (note that required fields are highlighted by
BOLD text):
FIELDS
KEY ACTION
AIR PROGRAM CODE(S)
ACTION TYPE
DATE SCHEDULED
DATE ACHIEVED
RESULTS CODE
PENALTY AMOUNT
RDE8
STAFF CODE
POLLUTANT CODE
CONTRACTOR ID
RDE16
NOTES
(Y-YES OR N-NO)
At least one-and all that are applicable
A Regional Action Type. Actions which are MDRs
require mapping to a National Action type.
Required for certain actions
Either the Date Scheduled or Date Achieved is required.
Date Achieved must be applied for application in
National analysis/reports.
As applicable, required for certain actions
Required if assessed
As applicable, required for certain actions
Optional
As applicable
Optional-considered obsolete
Optional
KEY ACTION: Identification of a key action is mandatory for action linking in HPV, FCE or
Non-HPV pathways. EFFECTIVE JUNE 2006: AFS will automatically indicate as key any day
zero action types. The National Action Types affected are:
HPV Pathways 2B, 2E, 2U, 2Z
FCE Pathways 5E, 5F, 5G, 5H
Non-HPV Pathways NH
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Historically, the field defaults to a NO value. Direct users of AFS indicated a "Y" for YES value
if the action is the key for a High Priority Violator (HPV) or Non-HPV pathway. Batch users of
AFS triggered this value by supplying the Key Action Number on the action transaction.
AIR PROGRAM CODE(S): Any applicable air program for a reported activity should be listed
on the action record. AFS will not accept an air program code that has not been documented in
Screens 302 (update) and Screen 502 (browse). Users should not enter only one air program if
more programs are applicable for the activity reported. Valid values are:
0 State Implementation Plan (SIP)
1 SIP Source under Federal Jurisdiction
3 Non-Federally Reportable Source
4 Chlorofluorocarbons (CFC) Tracking
6 Prevention of Significant Deterioration (PSD)
7 New Source Review (NSR)
8 National Emission Standards for Hazardous Air Pollutants (NESHAP)
9 New Source Performance Standards (NSPS)
A Acid Precipitation
F Federally Enforceable State Operating Permit - Non Title V (FESOP)
I Native American
M Maximum Achievable Control Technology (MACT) Section 63 NESHAP
V Title V Permits
ACTION TYPE: This field is the Regional Action Type identifying the activity. Each EPA
Region has its own action type table (please refer to Appendix 3a for a comprehensive listing of
Regional Action Types, Appendix 3b for a listing of Tribal Action Types, and Appendix 3c for
allowable duplicate action types) with values mapping into the National Action Type tables.
Users do not report activity using a National Action Type. The 2-digit Regional Action Type is
predefined in an action table. AFS will not accept a value that is not on record in the table.
Normally, action records are reported to AFS with unique action types and dates. There are a
few instances were actions happening on the same day are allowable. For example: A Full
Compliance Evaluation (FCE) at a source would not logically be completed twice on the same
day. A stack test, however, can be completed multiple times on a specific day with different
processes and pollutants involved in each test. Appendix 3c outlines the allowable National
Action types that can be reported multiple times using the same date. Users can use a special
code of "00" which is used in instances where the action table does not have a valid value for
use, and is not expected to be a recurring activity. For example: A source with an active High
Priority Violator (HPV) pathway suffers a fire, destroying most of the source. As this activity is
important to the HPV information, an AFS user may want to include this information in the HPV
pathway. There is no action type in the Regional table describing a fire. The user can report the
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fire using action type "00" with a mandatory description of "Fire". Use of action type "00"
requires the entry of a short description of the action. The Regional AFS Compliance Manager
should be contacted for addition of action types to the Regional table.
When requesting a new Regional Action Type or a change to an existing type, please provide the
following information to the appropriate Regional AFS Compliance Manager. This information
will be submitted to the System Administrator for application to the table:
* Regional Table to be changed:
* Action Type to be added/changed:
* Action Definition:
* Action Description-Long (up to 50 characters):
* Action Description-Short (up to 15 characters):
* Linkage to National Action Type:
DATE SCHEDULED: AFS provides space for reporting the scheduled date of an activity. This
field is optional reporting for most activities but can be required in Compliance Monitoring
Strategy (CMS) reporting. The reporting parameter is YYMMDD, with YY representing the last
two digits of a year (example: 2003 is reported as 03), MM as the 2-digit month (example: June
is reported as 06), and DD as the day of the month. Date Scheduled is an Enforcement
Sensitive field, with the exception of National Action Type CB or CC (Title V Annual
Compliance Certification Due/Received by the Permit Authority or EPA), and any regional
action type mapped to it. Either the Date Scheduled or Date Achieved is mandatory for action
reporting.
DATE ACHIEVED: This field is most frequently reported, and reflects the final date of an
activity. Please see discussions of individual action types for the definition of Date Achieved.
The reporting parameter is YYMMDD, with YY representing the last two digits of a year
(example: 2003 is reported as 03), MM as the 2-digit month (example: June is reported as 06),
and DD as the day of the month. Either the Date Scheduled or Date Achieved is mandatory for
action reporting.
RESULTS CODE: A two-digit alphanumeric code used to indicate the result of an activity. The
code must be a valid value on the Results Table. Each Region maintains its own Results Code
Table. This field is optional for most activity, but mandatory for Stack Test and Annual
Compliance Certification Reviewed reporting.
PENALTY AMOUNT: This field reports dollar amounts of penalties. In formal enforcement
actions, it defines the dollar amount of any cash penalty that is either 1) assessed (required) by an
administrative order, consent agreement/order, or consent decree; or 2) proposed under a civil
referral or civil filing. No decimal values are entered. See Section 5 for in-depth discussion of
the use of the Penalty field. In Supplemental Environmental Projects, the penalty field reports
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the dollar value of the project. Penalties exceeding the seven-digit limit of the PAM1 field in
AFS can be reported by entering the alpha K after the value of thousands of dollars. For
example, $5,000,000.00 could be reported as "5000K".
REGIONAL DATA ELEMENT 8 (RDE 8): This 2-digit field is optional for most activities, but
required in Annual Compliance Certification deviation reporting (an EPA requirement). It is
defined by users and used to maintain information relating to a plant action. In Title V Annual
Compliance Certification reporting, this field identifies a compliance status.
STAFF CODE: A 3-digit code identifying a staff member responsible for or associated with an
action. This code must be a valid value on the Staff Code table. Entry of values on the Staff
Code table requires a special access code on the user's security profile. Normally access to
update the Staff Code Table is provided to one user per state or local agency. Use of the Staff
Code field is optional to all users.
POLLUTANT CODE: A five-digit code identifying the pollutant of record for an action.
Reporting of the pollutant code is required for HPV Key Actions. Pollutant code may be
reported on stack test actions (highly recommended but not required).
CONTRACTOR ID: Use of this field is optional. The Contractor ID is a 12-digit alphanumeric
field used to identify asbestos contractors. The ID must be a valid value from the Contractor ID
Table. This field is considered obsolete.
REGIONAL DAT A ELEMENT 16 (RDE 16): This 25-digit optional field is defined by users
and used to maintain information relating to plant level actions.
ASSOCIATED DAY ZERO (KEY ACTION NUMBER): This field identifies key action
numbers an action may be associated or linked to and is system generated.
2. Full Compliance Evaluations (FCEs):
The definition of an FCE is extracted from the Clean Air Act Stationary Source Compliance
Monitoring Strategy, April 2001: A Full Compliance Evaluation is a comprehensive evaluation
of the compliance status of a facility. It addresses all regulated pollutants at all regulated
emission units. Furthermore, it addresses the current compliance status of each emission unit, as
well as the facility's continuing ability to maintain compliance at each emission unit.
A Full Compliance Evaluation should include the following:
A review of all required reports, and to the extent necessary, the underlying records. This
includes all monitored data reported to the regulatory agency (e.g., CEM and continuous
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parameter monitoring reports, malfunction reports, excess emission reports). It also includes
a review of Title V self-certifications, semi-annual monitoring and periodic monitoring
reports, and any other reports required by permit.
An assessment of control device and process operating conditions as appropriate. An on-site
visit to make this assessment may not be necessary based upon factors such as the
availability of continuous emission and periodic monitoring data, compliance certifications,
and deviation reports. Examples of source categories that may not require an on-site visit to
access compliance include, but are not limited to, gas-fired compressor stations, boilers in
large office and apartment buildings, peaking stations, and gas turbines.
A visible emission observation as needed.
A review of facility records and operating logs.
An assessment of process parameters such as feed rates, raw material compositions, and
process rates.
An assessment of control equipment performance parameters (e.g., water flow rates, pressure
drop, temperature, and electrostatic precipitator power levels).
A stack test where there is no other means for determining compliance with the emission
limits. In determining whether a stack test is necessary, States/locals should consider factors
such as: size of emission unit; time elapsed since last stack test; results of that test and
margin of compliance; condition of control equipment; and availability and results of
associated monitoring.
A Full Compliance Evaluation may be done piecemeal through a series of Partial
Compliance Evaluations.
A complete review of all data in AFS to assure reporting accuracy. This review should
include plant level data, air programs and operating status, air program pollutant class(es),
compliance status, attainment area status, HPV status, and default class(es) and status.
An FCE must be completed within the frequency indicated by the Compliance Monitoring
Strategy in order to avoid application of the automatic unknown compliance status utility.
FIELD NOTES
AFS REPORTING REQUIRED REPORTING-RECAP
AIR PROGRAM CODE(S): Required, usually "V" for Title V and any other
applicable air programs
ACTION TYPE: Regional equivalents of:
FE EPA Conducted FCE On Site
FZ EPA FCE Off Site
FS State Conducted FCE On Site
FF State FCE Off Site
DATE SCHEDULED: Optional
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DATE ACHIEVED: Required, reflect the date the onsite FCE is completed
or the date of the evaluation report (offsite FCE)
RESULTS CODE: Optional
PENALTY AMOUNT: Not appropriate for this action type
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Not required
CONTRACTOR ID Not required
RDE 16 Not required
3. Partial Compliance Evaluations (PCEs):
The definition for a PCE is extracted from the Clean Air Act Stationary Source Compliance
Monitoring Strategy, April 2001: A Partial Compliance Evaluation is a documented compliance
assessment focusing on a subset of regulated pollutants, regulatory requirements, or emission
units at a given facility. A PCE should be more comprehensive than a cursory review of
individual reports. It may be conducted solely for the purpose of evaluating a specific aspect of a
facility, or combined over the course of a year to satisfy the requirements of a Full Compliance
Evaluation. PCEs may include: Site Visits, Conferences, Review of Required Reports,
Compliance Reviews of individual Air Programs, Emission Inventory reviews, or other
activities. It is recommended that Regional values of PCEs describe the evaluating action taking
place, such as "Conference on Site" or "RATA Review".
FIELD NOTES
AFS REPORTING Required for Federal Reporters, Optional for
State/Local/Tribal Reporters
AIR PROGRAM CODE(S): Required, usually "V" for Title V and any other
applicable air programs
ACTION TYPE: Regional equivalent of:
ES EPA Conducted PCE On Site
EX EPA PCE Off Site
PS State Conducted PCE On Site
PX State PCE Off Site
The following optional action types are available for
use in reporting PCEs:
EE-EPA or PC-State/Local: Complaint Partial
Compliance Evaluation: Used for reporting the
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investigation of a complaint resulting in the on-site visit
of a stationary source.
EP-EPA or PP-State/Local: Permit Partial
Compliance Evaluation: Used for reporting pre-and
post-permit issuance activities, where an on-site visit is
necessary to review individual processes or installation
of equipment.
EM-EPA or PR-State/Local: Process Partial
Compliance Evaluation: Used for reporting the review
of one or more plant processes for compliance
purposes. For example, Maximum Achievable Control
Technology (MACT) notifications and resulting
compliance determinations.
EO-EPA or PO-State/Local: Partial Compliance
Evaluation On-Site Observation: Used for reporting
any on-site review of source to include visible
emissions or other observed activity.
DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID
RDE16
Optional
Required, can reflect either a review date or actual
date of visit.
Optional
Not appropriate for this action type
Not required
Not required
Not required
Not required
Not required.
4. Stack (Performance) Tests:
As taken from the 2003 National Stack Test Guidance: Stack testing is defined as any
standardized procedure of actions using calibrated tools to determine a rate or concentration in
order to verify emissions from a source or the accuracy of a monitor or gauge. It does not
include visible emission observations. The date a stack or performance test is completed is
documented in AFS, with a compliance determination (updating of compliance status, as
appropriate) from the results. Test results are reflected in the Results Codes (PP-PASS, FF-FAIL
or 99-Pending). Federal reporters are required to report the pollutants tested in the Pollutant
Code field on the action record. Pollutant Code reporting for State/Local/Tribal reporters is
optional; multiple actions on the same day with multiple pollutants are acceptable. There are
multiple action types for Stack Tests. They are:
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2A EPA Source Test Conducted: EPA test required, observed, and reviewed.
3 A Owner/Operator Conducted Source Test: Must be State/Local agency observed
and reviewed.
6C State Source Test Conducted: Must be State/Local agency observed and reviewed.
TE EPA Required Stack Test Not Observed: Owner/Operator Conducted test,
required by EPA, reviewed by EPA, but not observed by EPA
TO EPA Required Stack Test Observed: EPA required stack test, Owner/Operator
conducted, observed by EPA.
TR State Required Stack Test Not Observed: Owner/Operator Conducted test,
required by the State or Local Agency, reviewed but not observed by the State.
If the results of a stack test report are not known when reporting the stack test, a results code of
"99-Pending" may be used. However, the "Pending" results code is considered to be a
temporary value and is to be replaced with the pass/fail results code within 120 days of the date
of the stack test. Fixed Format Report 658, Pending Stack Tests Report, has been created to
assist with the ability to easily update these records. This report provides all stack test actions
with a pending code "99" for more than 120 days, along with a file of AFS action transactions to
facilitate reporting of actual results codes.
Action "TT/TS-EPA/State Receipt of Stack Test Report" has been added for the facilitation of
reporting High Priority Violator (HPV) cases involving failed stack tests where the results of the
stack test were not known when initially reported to AFS. The use of this optional action type
allows agencies reporting HPVs the opportunity to report a Day Zero action within timeliness
requirements, as this action documents the receipt of when the discovering agency first receives
information concerning a Federally-enforceable violation, consistent with the HPV Policy (see
HPV Policy, Section IVA), and would also be the Discovery Date. See Section 11, for more
information.
Action "SS/ST-EPA/State Non-MDR Stack Test" has been added for reporting performance tests
for purposes other than determining or demonstrating compliance. See the National Stack Test
Guidance of September 30, 2005 for full definitions of tests meeting the definition of this action
type. Should this test result in a failure, appropriate MDR stack test types (2A, 6C, TO, 3 A, TE,
TR) should be used to report the failure. The action should be reported using the SIP Air
Program Code. This action type is for optional use and is not included in official stack test
activity reports.
FIELD NOTES
AFS REPORTING: REQUIRED REPORT-RECAP
AIR PROGRAM CODE(S): Required, usually "V" for Title V and any other
applicable air programs
ACTION TYPE: Regional equivalent of:
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DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID
RDE16
2A EPA Source Test Conducted
3A Owner/Operator-Conducted Source Test
6C State Source Test Conducted
TE EPA Stack Test Not Observed
TO EPA Stack Test Observed
TR State Stack Test Not Observed
Optional
Required. Effective October 1, 2006: All Stack Test
actions should reflect the date of the actual test,
regardless of the review date. Date should reflect
the last day of actual test as per reference methods.
Required: PP-PASS, FF-FAIL, 99-PENDING
Not appropriate for this action type
Not required
Not required
Required reporting for Federal Reporters, Optional
reporting for State/Local/Tribal Reporter
Not required
Not required.
5. Investigations:
The definition of an Investigation is extracted from the Clean Air Act Stationary Source
Compliance Monitoring Strategy, April 2001: An Investigation is limited to a portion of a
facility, is more resource intensive, and involves a more in-depth assessment of a particular
issue. It usually is based on information discovered during a Full Compliance Evaluation, or as
the result of a targeted industry, regulatory, or statutory initiative. Also, an Investigation often
requires the use and analysis of information not available in EPA data systems. It is best used
when addressing issues that are difficult to evaluate during a routine FCE because of time
constraints, the type of preliminary field work required, and/or the level of analytical expertise
needed to determine compliance.
Investigations are tracked in AFS via two Action Types: Initiated and Completed. Initiated
action types are Enforcement Sensitive. At the start of an Investigation, the action types
documenting the initiated date should be added. At the completion of the Investigation (which
could span fiscal year time frames), the action types documenting the completion date should be
added.
FIELD
AFS REPORTING
NOTES
REQUIRED REPORTING-RECAP
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AIR PROGRAM CODE(S):
ACTION TYPE:
DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID
RDE16
Required, should reflect the applicable air programs
Regional equivalents of:
El EPA Investigation Initiated
EC EPA Investigation Conducted
SI State Investigation Initiated
SC State Investigation Conducted
Optional
Required. Actual dates of investigation initiated and
completion.
Not required
Not appropriate for this action type
Not required
Not required
Optional reporting, not required
Not required
Not required.
6. Notices of Violation:
A notice of violation (NOV) sent by EPA or the State/Local Agency informing a source that a
violation by the authority granted by Section 113 of the Clean Air Act as amended in 1990, or
similar State authority for a violation of the Clean Air Act has occurred. An NOV is considered
an informal enforcement action. No penalty is applied to a Notice of Violation. If an agency
has a Stipulated Penalty Demand Letter, or an NOV with a proposed penalty, then both the
NOV and the Administrative Order with Penalty action types should be reported.
FIELD NOTES
AFS REPORTING:
AIR PROGRAM CODE(S):
ACTION TYPE:
DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
REQUIRED REPORTING-RECAP
Required, should reflect the applicable air programs
Regional equivalent of:
6A EPA NOV Issued
7C State NOV Issued
Optional
Required. Signature date of the NOV letter.
Not required
Not appropriate for this action type (Proposed Penalties
or Stipulated Penalty Demand Letters should be reported as
an 8C-Administrative Order)
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RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Optional reporting, not required
CONTRACTOR ID Not required
RDE 16 Not required.
7. Administrative Orders:
DEFINITION: An administrative action (not civil or judicial) against a source with or without an
assessed penalty that has been determined by the proper authority for violating the Clean Air Act
as amended in 1990, or other State-delegated regulations. The penalty reported will be an
assessed cash penalty. These actions are addressing actions for High Priority Violator (HPV)
tracking, and are to be used in conjunction with action linking.
State and Local reporters use the State Administrative Order Issued to report activity not of a
civil or judicial nature. Additionally, if the agency uses a stipulated penalty demand letter, or
submits a Notice of Violation with proposed penalties to a source, an administrative order in
addition to the NOV action type should be reported to AFS. All state penalties reported within
the Administrative Order action should be assessed cash penalties and should not include any
injunctive relief, Beneficial or Supplemental Environmental Project costs.
EPA Administrative Orders do not have any penalties applied. EPA Administrative Penalty
Orders (APOs) are a three-step reporting process starting with the 7F-113(D) Administrative
Penalty Order Filed, with the Date Achieved reflecting the filing date of the action and the
penalty reflecting the proposed penalty from the order. It is followed by the second step, C2-
113(D) Administrative Penalty Order Recalculated, which contains the mitigated assessed
penalty amount. This second action documents the APO, and provides the record of formal and
final penalty. The last activity, C3-APO Collected, documents when the assessed penalty is paid.
All enforcement tracking is done using the C2-113(D) Administrative Penalty Order
Recalculated action type.
AFS REPORTING: REQUIRED REPORTING-RECAP
AIR PROGRAM CODE(S): Required, should reflect the applicable air
programs
ACTION TYPE: Regional equivalents of:
8A Federal 113(A) Order Issued
8C State Administrative Order Issued
Federal APOs
7F EPA 113(D) Complaint Filed
C2 EPA 113(D) Recalculated-CAFO
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C3 EPA 113(D) Collected
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Date of the official instrument.
RESULTS CODE: Not required.
PENALTY AMOUNT: 8C- State Final Assessed Cash Penalty
7F-EPA Proposed Cash Penalty
C2-EPA Final Assessed Cash Penalty
C3- EPA Assessed Cash Penalty Paid
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Optional reporting, not required
CONTRACTOR ID: Not required
RDE 16 Not required.
8. Consent Decrees:
A decree signed by the primary enforcement authority, the source, and by a court requiring a
source violating an applicable Federal or SIP regulation to attain compliance by means specified
in the decree. Consent Decrees and consent agreements should be tracked here if they are
formally signed. This is an addressing action for a high priority violator. Penalties reported are
the assessed dollar amount of any cash civil penalty. This action is also used for Administrative
Consent Decrees.
AFS REPORTING: REQUIRED REPORTING-RECAP
AIR PROGRAM CODE(S): Required, should reflect the applicable air
programs
ACTION TYPE: Regional equivalents of:
6B EPA Court Consent Decree
2D State Court Consent Decree
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Date Decree entered in State or
Federal Court
RESULTS CODE: Not required.
PENALTY AMOUNT: Assessed Cash Penalty.
RDE8: Not required
STAFF CODE: Not required
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POLLUTANT CODE: Optional reporting, not required
CONTRACTOR ID: Not required
RDE 16 Not required.
9. Civil Referrals:
Federal Civil Referrals: Action taken by EPA to file a civil complaint in Federal court pursuant
to the authority granted under State law for violating applicable State regulations or State-
delegated Federal regulations. Additionally, this action is to be used in the preparation of a
litigation report to initiate a Federal civil action against a noncomplying source and submittal to
Headquarters is imminent (to be counted here the litigation report must have the Regional Air
Director approval). Penalties reported are the assessed dollar amount of any cash civil penalty.
This is an addressing action for a high priority violation. This action is Enforcement Sensitive.
If this action is used in a High Priority Violator case, action type OT is also required.
AFS REPORTING: REQUIRED REPORTING-RECAP
AIR PROGRAM CODE(S): Required, should reflect the applicable air
programs
ACTION TYPE: Regional equivalents of:
4B EPA Civil Referral
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Signature date of litigation report.
RESULTS CODE: Not required.
PENALTY AMOUNT: Proposed Penalty
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Optional reporting, not required
CONTRACTOR ID: Not required
RDE 16 Not required.
State Civil Referral: An action taken by the State or local agency against a source resulting in a
civil complaint being sent to the State Attorney General. This is different from a State Civil
Action (action type 9C) which is the actual filing of a civil complaint against a source by the
State Attorney General in a State court. This action is an addressing action for high priority
violations and is to be used in action linking. This action is Enforcement Sensitive. If this action
is used in an HPV case, action type OT is also required.
AFS REPORTING: REQUIRED REPORTING-RECAP
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AIR PROGRAM CODE(S): Required, should reflect the applicable air
programs
ACTION TYPE: Regional equivalents of:
IE Civil Referral to State Attorney
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Signature date of referral
document.
RESULTS CODE: Not required.
PENALTY AMOUNT: Not required.
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Optional reporting, not required
CONTRACTOR ID: Not required
RDE 16 Not required.
10. Civil Actions
Federal Civil Actions: Reporting of Federal Civil Actions has not been well-documented in AFS.
Reporting of this activity is done in the Integrated Compliance Information System (ICIS).
During FY04, an AFS workgroup is chartered to review and document how AFS should handle
this type of action. More guidance is necessary for Federal Civil Action reporting in conjunction
with High Priority Violator Cases. At this time, the only action type available for reporting the
outcome of a Federal Civil action is 7B-EPA Civil Penalty Assessed.
State Civil Action: The filing of a civil compliant against a source by the State Attorney General
in a State Court. Action is taken by a State or Local Agency to file a civil complaint against a
source in the State Court pursuant to the authority granted under State Law for violating
applicable SIP or State-delegated Federal regulations. Additionally, this action type is used to
document settlement proceedings. This action is an addressing action for high priority violations
and is to be used in action linking.
AFS REPORTING: REQUIRED REPORTING-RECAP
AIR PROGRAM CODE(S): Required, should reflect the applicable air
programs
ACTION TYPE: Regional equivalents of:
9C State Civil Action
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Date of Court filing or Decision
Date.
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RESULTS CODE: Not required.
PENALTY AMOUNT: Assessed Cash Penalty, if reporting
settlement
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Optional reporting, not required
CONTRACTOR ID: Not required
RDE 16 Not required.
11. High Priority Violator (HPV) Day Zero
DEFINITION: A High Priority Violator (HPV) is identified one of three ways:
1. The violation may fit within one of the ten General HPV Criteria identified in the HPV
Policy of June 1999.
2. The violation may lead to emissions or parameter violations that fit within the HPV Matrix
Criteria (reference HPV Policy of June 1999).
3. The violation may be categorized as an HPV on a discretionary basis subject to the mutual
agreement of the State/Local agency and EPA.
HPV cases are tracked in AFS via action linkage with the following information:
1. Day Zero Action Type: Defines a state/local, joint, or Federal lead and a start date. Indicates
the start of an HPV pathway and requires a compliance status change to violation.
2. Violation Type Code: A three-digit code defining the reason why a source has met the
definition of HPV. Code tables can be found in AFS in the Utilities, under Descriptions,
Violation Codes. Additionally, the code tables are provided in this section.
3. Discovery Date: The date of discovery is usually defined by one of the following activities:
* A Full Compliance Evaluation;
* A Partial Compliance Evaluation (On- or Off-Site Evaluations);
* A Title V Annual Compliance CertificationDue/Received or Reviewed;
* Stack Tests
* Receipt of Stack Test Report or
* Investigations.
4. Violating Pollutant(s): Pollutant(s) in violation. If the violation does not involve a specific
pollutant (i.e. permit paperwork violations), use the pollutant code "FACIL" Pollutant codes
must be used to capture violating pollutant(s). If you have a substance without an existing
pollutant code, please contact the AFS Helpline (1-800-367-1044) for assistance.
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5. Addressing Action: Usually an enforcement action or civil referral. This section contains a
table defining addressing action types.
6. Resolving Action: An action that closes out the violation, and requires a compliance status
change to compliance.
Each of these milestones has reporting criteria and the reporter must link all appropriate actions
to the Day Zero action in AFS. Linkage is started by indicating a Key Action. [Note: Day Zero
and the Addressing Action MUST NOT be recorded on the same day.]
In August 2006, AFS was enhanced to check for the presence of an addressing action when a
resolution action is applied. Prior to this, AFS allowed pathways to be resolved with no
addressing action linked into the pathway. Pathways in AFS prior to this time (August 24, 2008)
were not affected by this enhancement.
On October 3, 2008, another enhancement to HPV data provides retrievable acronyms for HPV
addressing and resolution actions. This enhancement also required that an addressing action in a
pathway could not be changed or deleted if the pathway as resolved. These enhancements were
added to ensure data quality and correct reporting of pathways. The following table provides the
new retrievable HPV fields:
FIELD NAME
DISCOVERY
ADDRESSING
RESOLUTION
Discovery Action Date
Discovery Regional Action Type
Discovery Regional Action Type Description
(generated not stored)
Addressing Action Date
Addressing Regional Action Type
Addressing Regional Action Type Description
(generated not stored)
Addressing Action Penalty Amount
Resolution Action Date
Resolution Regional Action Type
Resolution Regional Action Type Description
(generated not stored)
ACROYNM
DADT
DATP
DADS
AADT
AATP
AADS
AAPA
RADT
RATP
RADS
The October 2008 enhancement also identifies the individual milestones within the pathway so
the user can easily identify discovery, addressing and resolution actions. A "D", "A" or "R" are
placed to the left of the actions within the pathway, as seen by this example:
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AIR PROGRAM CODE(S) : 0 9 8 V M 6 STATE REGISTRATION NUMBER: TEAM 0314
COMP STAT (EPA/ST) : 5 / 1 CLASS: A STAFF: BAF GOVT FACIL: 0 HPV: F
LEAD AGENCY: S VIOLATION IDENTIFIER: S VIOLATING PLLTS: THAP
VIOLATION TYPE CODE: GC2
DAY 60: 061024 DAY 150: 070123 DAY 270: 070523 DAY 300: 070622
DAYS USED TO ADDRESS: 66 UNADDRESSED DAYS: 0
ACTION ACTION DATE DATE PENALTY RESULTS RESULTS ST
NUM/IND/TYP DESCRIPTION SCHED ACHVD DESCRIPTION PRIV
284 N6 STATE DAY ZERO 060825 060825 01 ACTION ACHIEVED N
289 PD PENALTY PAID 061230 061113 0022000 01 ACTION ACHIEVED N
290 A Z3 ST ADM PEN ORD 061030 061030 0022000 01 ACTION ACHIEVED N
303 D 44 STTE PT INSP 060711 060711 01 ACTION ACHIEVED N
452 R V2 VIOLATE RESOLVE 080822 080822 01 ACTION ACHIEVED N
Guidance on the HPV policy and AFS reporting can be found at:
http://www.epa.gov/compliance/resources/policies/civil/caa/stationary/hpvmanualrevised.pdf
Regions are encouraged to use the 620 Fixed Report, HPV Pathway Summary Report, to track
cases with state/local agencies. This report will include the Day Zero action, information on the
lead, and all linked actions including the first comment on the Day Zero action. It is
recommended that the lead agency provide an action comment with information concerning the
violation. The first comment attached to the key action record will be provided on the 620
report. EPA uses the 653 Fixed Report, HPV Summary Report, to track the days used to address
and track unaddressed cases. [Note: Compliance status needs to be updated during the HPV
process.] Additionally, the 659 Fixed Report, High Priority Violator Report, provides HPV
tracking information with a stream-lined summary report. It also includes resolution dates not
found in the 653 report.
DAY ZERO DEFINITION: Day Zero will ordinarily be no later than 45 days from the day the
violation was discovered. For violations requiring additional information, Day Zero may be
extended to 90 days from the date the violation is discovered or the date of receipt of the
additional information. If a violation is self-reported, Day Zero will be 30 days from the date the
agency receives the information. A Notice of Violation action can document the Day Zero
action. In addition to reporting the Day Zero and action linking, the plant compliance
status should be changed to reflect violation. Day Zero actions that have been added to AFS
in error should be deleted from the database. If an HPV case is discontinued (no enforcement
action will be taken), one of the following methods should be used to close out the case:
If the facility is in compliance, use action type 2K/7G-Source Returned to Compliance
with no Further Action required. These action types resolve the pathway.
If the facility is still in violation but the case is being dropped for litigation risk or other
related issues, a written record to the file is required and action type C7-Closeout Memo
Issued should be entered. This action type will resolve the pathway.
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AFS REPORTING:
AIR PROGRAM CODE(S):
ACTION TYPE:
DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID:
RDE16
VIOLATING POLLUTANTS:
LEAD AGENCY:
VIOLATION IDENTIFIER:
VIOLATION TYPE CODES:
ACTION LINKING FOR HPV
REQUIRED REPORTING-RECAP
Required, should reflect the applicable air programs
Regional equivalents of:
2Z EPA Day Zero
2E State Day Zero
2U Enforcement Lead is Unassigned
2B Shared Enforcement Lead
Optional
Required. Date determined by policy.
Not required.
Not required.
Not required
Not required
A pollutant can be reported here or reported on the
HPV linkage screen under Violating Pollutants.
Not required
Not required.
Required, report using pollutant codes.
Not required, but recommended. AFS will also identify
a pathway by its Day Zero action type.
Not required.
Required. See following tables for values.
CASES IS REQUIRED
HPV DISCOVERY DATE: On October 1, 2005, the minimum data requirements for AFS were
expanded to include the activity that lead to the discovery of an HPV and is required to be
identified within the appropriate violation pathway in AFS. AFS has been enhanced to include
the discovery date of a violation pathway on the HPV Flag Action Pathway Matrix screen
(Screen 515). Actions defining discovery (Full Compliance Evaluations, Partial Compliance
Evaluations, Stack Tests, Investigations, Receipt of Stack Test Report and Title V Annual
Compliance Certification Review or Due/Received) linked within an HPV pathway will trigger
the summary on the HPV Flag Action Pathway Matrix screen.
Use of the National Action Type "TT/TS-EPA/State Receipt of Stack Test Report" is used when
the stack test results were not known at the time when the action was reported to AFS. When
this action is used in an HPV pathway, it will be used as the HPV Discovery Date versus the
stack test action. This action type is intended to be used in conjunction with appropriate stack
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test actions, however, AFS will use the TT/TS action type equivalents to document HPV
Discovery Date. Use of this action will document the receipt of when the discovering agency
first receives information concerning a Federally-enforceable violation, consistent with the HPV
Policy.
In November 2006, the AFS Compliance Managers voted to add the addition of Title V Annual
Compliance Certification Due/Received actions as an HPV Discovery Date. This action was
added as many HPV situations were determined due to an overdue TV Annual Compliance
Certification. The Due/Received action captures the date of the discovery in the Date Achieved
field and should be used as the Discovery Date action.
Additionally, retrievable acronyms have been created in order to facilitate review and analysis of
this information:
AFS
Acronym
DADT
DATP
DADS
Description
FIPV Discovery
YYYYMMDD
FIPV Discovery
Regional Action
Date, can be used as selection or output criteria,
date format is
Action Type, can only be used as output, provides the
Type used to define the HPV Discovery Date
HPV Discovery Action Description, can only be used as output,
description of the Regional Action Type used to define the HPV
Date
reflects the
Discovery
The following sample screen print from AFS depicts the addition of the HPV Discovery Date:
AFP515
AFM5151
00000 SAMPLE PLANT 123 MAIN STREET
AIR PROGRAM CODES: M MACT (SECTIO V TITLE V PERM 0 SIP
STATE COMPL STAT: 1 IN VIOLATION - NO EPA COMPL STAT: 5 MEETING COMPLIANCE
CURR HPV FLAG: S EFF DATE: 20041029 FLAG SOURCE: S ACTION NO: 439
RESOLVED ACTION
TYPE/DATE ACHIEVED
Users are also encouraged to enter a short comment describing the violation on the Day Zero
Action.
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HPV MATRIX VIOLATION CODE TABLE
DESCRIPTION TYPE: VC -VIOLATION TYPE CODES
GC1
Fail to Obtain PSD or NSR Permit: Failure to obtain a PSD permit (and/or to
install BACT), an NSR permit (and/or to install LAER or obtain offsets)
and/or a permit for a major modification of either.
GC2
Viol. Of Air Toxics Requirements: Violation of air toxics requirement (i.e.
NESHAP, MACT) that either results in excess emissions or violates
operating parameter restrictions.
GC3
Violation that Affects Synthetic Minor Status: Violation by a synthetic minor
of an emission limit or permit condition that affects the source's PSD, NSR,
or Title V status.
GC4
Enforcement Violation: Violation of any substantive term of any Local, State,
or Federal order, consent decree or administrative order.
GC5
Title V Certification Violation: Substantial violation of the source's Title V
certification obligations.
GC6
Title V Permit Application Violation: Substantial violation of the source's
obligation to submit a Title V permit application.
GC7
Testing, Monitoring, Recordkeeping, or Reporting Violation: Violations that
involve testing, monitoring, recordkeeping, or reporting that substantially
interfere with enforcement or determining the source's compliance with
applicable emission limits.
GC8
Emission Violation: Violation of an allowable emission limit detected during a
reference method stack test.
GC9
Chronic or Recalcitrant Violation: CAA violations by chronic or recalcitrant
violators.
G10
Section 112(r) Violation: Substantial violation of CAA Section 112(r)
requirements.
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HPV
MATRIX
CODES
MATRIX
CODE
M1A
M1B
M1C
M2A
M2B
AFS DESCRIPTION
Any violation of
emission limit
detected via stack
testing.
Violation of emission
limits > 15% via
sampling
Violation of emission
limits > the SST
(Supplemental
Significant
Threshold)
Violation of Direct
Surrogate for >5% of
limit for >3% of OT
(operating time)
Violation of Direct
Surrogate for >50%
of OT (operating
time).
VIOLATION
Violation of Allowable Emissions
Limitations, reference HPV
Matrix Criteria 1A, reference
method stack testing.
Violation of allowable emissions
limitations, reference HPV Policy
Matrix Criteria 1B, coatings
analysis, fuel samples or other
process material sampling.
Violation of allowable emissions
limitations, reference HPV Policy
Matrix Criteria 1B, coatings
analysis, fuel samples or other
process material sampling.
Violation of parameter emissions
limitations, reference HPV Policy
Matrix Criteria 2A,
continuous/periodic parameter
monitoring.
Violation of parameter emissions
limitations, reference HPV Policy
Matrix Criteria 2A,
continuous/periodic parameter
monitoring.
METHOD OF
DETECTION
Stack Testing
Coatings analysis, fuel
samples, other
process materials
sampling or
raw/process materials
usage reports.
Coatings analysis, fuel
samples, other
process materials
sampling or
raw/process materials
usage reports.
Continuous/Periodic
Parameter Monitoring
(includes indicators of
control device
performance).
Continuous/Periodic
Parameter Monitoring
(includes indicators of
control device
performance).
MAPS TO
POLICY
MATRIX #
1 -Emission
Violation
Detected by
Stack Test
2-Emission
Violation
Using
Process/Form
ulation Data
2-Emission
Violation
using
Process/Form
ulation Data
3-Surrogate
Limit Violation
3-Surrogate
Limit Violation
STANDARD
Any applicable
requirement
Any applicable
requirement
Any applicable
requirement
Any applicable
requirement
Any applicable
requirement
SUPPLEMENTA
L SIGNIFICANT
THRESHOLDi
CO 23 Ib/hr,
NOX 9 Ib/hr,
S02 9 Ib/hr,
VOC 9 Ib/hr,
PM 6 Ib/hr,
PM1 03 Ib/hr
% IN EXCESS OF
REFERENCE
LIMIT/PARAMETER
Any violation of the
applicable standard
> 15% of the
applicable emission
limitation
> the SST. 1
> 5% of the applicable
parameter limit
N/A
N/A
N/A
FOR
% OF TIME IN EXCESS
OF REFERENCE LIMIT
>3% of the operating time
during the reporting
period.
Any exceedance of the
parameter limit for >50%
of the operating time
during the reporting
period, s
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HPV
MATRIX
CODES
MATRIX
CODE
M2C
MSA
MSB
M3C
M3D
AFS DESCRIPTION
Violation of Direct
Surrogate of >25%
for 2 reporting
periods.
Violation of non-
opacity standard via
OEM of >1 5% for
>5% of operating
time.
Violation of non-
opacity standard via
OEM of the SST
(Supplemental
Significant
Threshold).
Violation of non-
opacity standard via
OEM of >1 5% for 2
reporting periods
Violation of non-
opacity standard via
CEMof>50%ofthe
operating time during
the reporting period.
VIOLATION
Violation of parameter emissions
limitations, reference HPV Policy
Matrix Criteria 2A,
continuous/periodic parameter
monitoring.
Violation of applicable standards
(non-opacity), reference HPV
Policy Matrix Criteria 3A,
continuous emissions
monitoring.
Violation of applicable standards
(non-opacity), reference HPV
Policy Matrix Criteria 3A,
continuous emissions
monitoring.
Violation of applicable standards
(non-opacity), reference HPV
Policy Matrix Criteria 3A,
continuous emissions
monitoring.
Violation of applicable standards
(non-opacity), reference HPV
Policy Matrix Criteria 3A,
continuous emissions
monitoring.
METHOD OF
DETECTION
Continuous/Periodic
Parameter Monitoring
(includes indicators of
control device
performance).
Continuous Emissions
Monitoring (where
CEM is certified under
federal performance
specifications).
Continuous Emissions
Monitoring (where
CEM is certified under
federal performance
specifications).
Continuous Emissions
Monitoring (where
CEM is certified under
federal performance
specifications).
Continuous Emissions
Monitoring (where
CEM is certified under
federal performance
specifications).
MAPS TO
POLICY
MATRIX #
3-Surrogate
Limit Violation
4-CEM
Detected
Violation
4-CEM
Detected
Violation
4-CEM
Detected
Violation
4-CEM
Detected
Violation
STANDARD
Any applicable
requirement
<=24 hour
averaging
period
<=24 hour
averaging
period
<=24 hour
averaging
period
<=24 hour
averaging
period
SUPPLEMENTA
L SIGNIFICANT
THRESHOLDi
CO 23 Ib/hr
NOX 9 Ib/hr
SO2 9 Ib/hr
VOC 9 Ib/hr
% IN EXCESS OF
REFERENCE
LIMIT/PARAMETER
Any exceedance >
15% of the applicable
standard.
Any exceedance of
the SST.
Any exceedance Of
15% of the applicable
standard.
FOR
FOR
% OF TIME IN EXCESS
OF REFERENCE LIMIT
Any exceedance of the
parameter limit for >25%
of the operating time
during the reporting
period, continuing through
the subsequent
consecutive reporting
period, s
>5% of the operating time
during the reporting
period. 4 6
>3% of the operating time
during two consecutive
reporting periods. 4 e
Any exceedance Of the
reference limit for >50%
of the operating time
during the reporting
period. 3
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HPV
MATRIX
CODES
MATRIX
CODE
M3E
M3F
M4A
M4B
M4C
M4D
AFS DESCRIPTION
Violation of non-
opacity standard via
OEM of >25% during
two consecutive
reporting periods.
Any violation of non-
opacity (>24 hours
standard) via CEM.
Violation of opacity
standards (0-20%)
via Continuous
Opacity Monitoring
(COM).
Violations of opacity
standards >3% of
operating time via
Continuous Opacity
Monitoring during
two consecutive
reporting periods.
Violation of opacity
standards (> 20%)
via Continuous
Opacity Monitoring
(COM) for >5% of
operating Time.
Violation of opacity
standards (>20%) via
Continuous Opacity
Monitoring (COM) for
5% operating time.
VIOLATION
Violation of applicable standards
(non-opacity), reference HPV
Policy Matrix Criteria 3A,
continuous emissions
monitoring.
Violation of applicable standards
(non-opacity), reference HPV
Policy Matrix Criteria 3A,
continuous emissions
monitoring.
Violation of applicable standards
(opacity), reference HPV Policy
Matrix Criteria 4A, continuous
opacity monitoring. 2
METHOD OF
DETECTION
Continuous Emissions
Monitoring (where
CEM is certified under
federal performance
specifications).
Continuous Emissions
Monitoring (where
CEM is certified under
federal performance
specifications).
Continuous Opacity
Monitoring (COM)
Continuous Opacity
Monitoring (COM)
Continuous Opacity
Monitoring (COM)
Continuous Opacity
Monitoring (COM)
MAPS TO
POLICY
MATRIX #
4-CEM
Detected
Violation
4-CEM
Detected
Violation
5-Opacity
Violations
5-Opacity
Violations
5-Opacity
Violations
STANDARD
<=24 hour
averaging
period
>24 hour
averaging
period
0-20% opacity
0-20% opacity
> 20% opacity
> 20% opacity
SUPPLEMENTA
L SIGNIFICANT
THRESHOLDi
% IN EXCESS OF
REFERENCE
LIMIT/PARAMETER
Any violation of the
applicable standard.
>5% opacity over the
limit
>5% opacity over the
limit
>1 0% opacity over the
limit
>10% opacity over the
limit
N/A
FOR
FOR
% OF TIME IN EXCESS
OF REFERENCE LIMIT
Any exceedance of the
parameter limit for >25%
of the operating time
during the reporting
period, continuing through
the subsequent
consecutive reporting
period, s
>5% of the operating time
during the reporting
period. 4 6
>5% of the operating time
during the reporting
period. 4 6
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HPV
MATRIX
CODES
MATRIX
CODE
M4E
M4F
DIS
AFS DESCRIPTION
Violation of opacity
standards (0-20%)
via Method 9 VE
Readings.
Violation of opacity
standards (>20%) via
Method 9 VE
Readings.
Discretionary HPV
VIOLATION
Violation of applicable standards
(opacity), reference HPV Policy
Matrix Criteria 4B, Method 9
Visual Emissions Readings. 2
Violation of applicable opacity
standards (averaging period of
6-minute block averages),
reference HPV Matrix Criteria 5.
HPV definition subject to mutual
agreement of the State/Local
Agency and EPA.
METHOD OF
DETECTION
Method 9 VE
Readings
Method 9 VE
Readings
Mutual Agreement
MAPS TO
POLICY
MATRIX #
5-Opacity
Violations
5-Opacity
Violations
Not
Applicable-
Discretionary
STANDARD
0-20% opacity
> 20% opacity
Can be major
or minor source
SUPPLEMENTA
L SIGNIFICANT
THRESHOLDi
% IN EXCESS OF
REFERENCE
LIMIT/PARAMETER
>50% over limit
>25% over limit
AND
AND
% OF TIME IN EXCESS
OF REFERENCE LIMIT
Any violation of
SIP/NSPS limits, s
Footnotes:
1. Supplemental Significant Threshold is based on PSD significant levels. The significant threshold value is the Ib/hr emission
rate at 8760 hours which would result in PSD review.
2. Based on the applicable averaging period (e.g. 6-minute block averages).
3. For the first reporting period. If exceedance of the operating time during the first reporting period evaluated, and if such
exceedances continue during the subsequent consecutive reporting period, the exceedances will be considered high priority
violations for both reporting periods if the percent of time in excess exceeds 25% of the operating time during the second
reporting period.
4. For the first reporting period. If exceedances occur for more than 3% of the operating time during the first reporting period
evaluated, and if such exceedances continue during the subsequent consecutive reporting period, the exceedances will be
considered high priority violations for both reporting periods if the percent of time in excess exceeds 3% of the operating time
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during the second reporting period.
5. Unless the state or local agency concludes that 1) the cause of the violation has been corrected within 30 days and the source
has returned to compliance, are 2) the source was in compliance with an applicable mass limit at the time the Method 9 visual
reading was taken.
6. This would not include any federally approved exempt period (e.g., startup/shutdown/malfunction 40 CFR 60.11), since these
would not be violations.
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12. High Priority Violator (HPV) Lead Changes:
LEAD CHANGE DEFINITION: Lead changes (From Federal to State lead, from State to
Federal Lead, or Joint Lead) on a violation may be made at any time. Timely and appropriate
enforcement is extended to 300 days in case of a lead change. Cases may be assumed by EPA if
addressing/resolution actions have not taken place by Day 270. Lead changes are added to an
existing pathway and DO NOT change the day zero action date.
AIR PROGRAM CODE(S): Required, should reflect the applicable air programs
ACTION TYPE: Regional equivalents of:
DY Lead Changed to Federal Enforcement
DB Lead Changed to Shared Enforcement
DS Lead Changed to State Enforcement
2B Shared Enforcement Lead (Joint)
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Date of lead change.
RESULTS CODE: Not required.
PENALTY AMOUNT: Not required.
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Encouraged, lead pollutant should be reported.
CONTRACTOR ID: Not required
RDE 16 Not required.
ACTION LINKING FOR HPV CASES IS REQUIRED
13. High Priority Violator (HPV) Addressing and Resolving Actions:
ADDRESSING ACTION DEFINITION: By Day 270 (if there has been no lead change), the
violation should be either Resolved or Addressed. Addressing Actions include: Administrative
Orders, Civil or Criminal Referrals, Administratively Addressed with No Formal Enforcement
Action, SIP Revisions, Civil or Criminal Actions or Administrative Penalty Orders. In the case
of a civil or criminal referral, an additional action of "OT" Other Addressing Action will need to
be entered and linked to the Day Zero. As the Civil and Criminal Referral action types are
Enforcement Sensitive, the OT action will ensure that the violation is correctly addressed in
extracts to systems like the Online Targeting Information System (OTIS) and the Enforcement
Compliance History Online (ECHO) system. Addressed violations could have a compliance
status change from violation to meeting schedule. HPVs addressed but not resolved need to
reflect a compliance status of noncompliance or meeting schedule. See the following chart
for a list of addressing and resolving action types.
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VIOLATION RESOLVED DEFINITION: Source compliance is confirmed, all penalties are
collected, all activity identified in a Supplemental Enforcement Project (SEP) and all injunctive
relief is completed. After action reporting and linking, compliance status should be
returned to compliance. See the following chart for a list of addressing and resolving action
types.
AFS REPORTING FOR ADDRESSING AND RESOLVING ACTIONS:
AIR PROGRAM CODE(S): Required, should reflect the applicable air programs
ACTION TYPE: Regional equivalents of action types on the following
chart
DATE SCHEDULED: Optional
DATE ACHIEVED: Required. Date determined by activity.
RESULTS CODE: Not required.
PENALTY AMOUNT: Assessed cash penalties on the formal enforcement
addressing action (not the resolving action).
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Encouraged, lead pollutant should be reported on
the Day Zero action.
CONTRACTOR ID: Not required
RDE 16 Not required.
ACTION LINKING FOR HPV CASES IS REQUIRED
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NATIONAL ACTION TYPES FOR ADDRESSING OR RESOLVING HIGH
PRIORITY VIOLATOR CASES IN AFS
ACT DESCRIPTION ADDRESS RESOLVE
C3 EPA 113 (D) ADMIN PENALTY COLLECTED X
C7 CLOSEOUT MEMO ISSUED X
OT OTHER ADDRESSING ACTION (USED IN X
CONJUNCTION WITH CIVIL REFERRALS)
VR VIOLATION RESOLVED X
WD EPA 113(D) WITHDRAWN X
2D STATE COURT CONSENT DECREE X
2K COMPL BY STATE, NO ACTION REQUIRED X
(ADMINISTRATIVELY RESOLVED-NO FORMAL
ENFORCEMENT ACTION)
2L PROPOSED SIP REVISION WILL LEAD TO X
COMPLIANCE
2M PROPOSED SIP/FIP REVISION WILL LEAD TO X
COMPLIANCE
6B EPA COURT CONSENT DECREE X
7F EPA 113 (D) APO COMPLAINT FILED X
7G COMPL BY EPA, NO ACTION REQUIRED X
(ADMINISTRATIVELY RESOLVED-NO FORMAL
ENFORCEMENT ACTION)
8 A EPA 113 (A) ORDER IS SUED X
8C STATE ADMIN ORDER IS SUED X
9C STATE CIVIL ACTION X
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14. Non-HPV Day Zero:
This action type starts a pathway for non-HPV instances. The linkage feature of AFS has proven
to be very versatile and useful, and users had requested the ability to link up like actions similar
to the HPV pathways. This use of this action type is not mandatory and is available at user
discretion. The 620 report provides the choice of a Non-HPV pathway, so a pathway summary
report can be generated.
USE OF THIS ACTION TYPE IS OPTIONAL
AIR PROGRAM CODE(S): Required, should reflect the applicable air programs
ACTION TYPE: Regional equivalents of:
NH-Non-HPV Day Zero
DATE SCHEDULED: Optional
DATE ACHIEVED: Date Achieved or Schedule is mandatory.
RESULTS CODE: Not required.
PENALTY AMOUNT: Not required.
RDE8: Not required
STAFF CODE: Not required
POLLUTANT CODE: Not required
CONTRACTOR ID: Not required
RDE 16 Not required.
ACTION LINKING IS REQUIRED WHEN USING THIS OPTIONAL ACTION TYPE.
15. Dropped HPV Cases
There are instances when a violation is dropped with no further enforcement activity. The source
may or may not be in compliance. If the source is not in compliance the use of the National
Action Types 2K/7G-Source Returned to Compliance by State/EPA, is not appropriate. In this
instance, the National Action Type C7-Closeout Memo Issued, is recommended for closing out
the pathway. The memo referred to in the action type does not have to a formal memorandum or
letter to the source involved, it is assumed to be an accounting of the reasons for dropping
enforcement action.
16. Title V Annual Compliance Certifications Date Due and Received
DEFINITION: As required by the Compliance Monitoring Strategy (CMS) of April 2001,
Regions shall enter the date a Title V Annual Compliance Certification (ACC) is due and
received unless otherwise negotiated. Due dates are normally determined by the Permit
Authority and may reflect a grace period before a source is considered to be late in submitting
the ACC. Received dates are post mark dates on the ACC. In case of electronic submission, the
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date received is the date submitted to the reviewing agency. Compliance status is to be reported
in the Results Code field: MC=Compliance, MV=Violation, MU=Unknown. Deviations are to
be reported by EPA in the RDE8 field: Y=Yes, N=No, or a number of deviations reported may
be entered.
AFS REPORTING:
AIR PROGRAM CODE(S):
ACTION TYPE:
DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID:
RDE16
REQUIRED REPORTING-RECAP
Required, Should reflect "V" for Title V
Regional equivalents of:
CC EPA TV ACC Due/Received
CB Permit Authority TV ACC Due/Receive
(as negotiated)
Due Date, determined by Permitting
Authority
Received date, should reflect the post mark
on the certification.
Required by EPA, reports compliance:
MC=Compliance
MV=Violation
MU=Unknown
Not required.
Required by EPA, reports deviations:
Y=Yes
N=No
Or number of deviations may be reported.
State/Local agencies are encouraged to report
this information, but it is not required.
Not required
Not required.
Not required
Not required.
17. Title V Annual Compliance Certification Reviews:
As required by the Compliance Monitoring Strategy (CMS) of April 2001, EPA or State/Local
Agency review of an annual compliance certification submitted by a source which is permitted
under Title V of the Clean Air Act as amended in 1990. Compliance status is to be reported in
the Results Code field: MC=Compliance, MV=Violation, MU=Unknown. Deviations are to be
reported by EPA in the RDE8 field: Y=Yes, N=No, or a number of deviations reported may be
entered.
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AFS REPORTING:
AIR PROGRAM CODE(S):
ACTION TYPE:
DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID:
RDE16
REQUIRED REPORTING-RECAP
Required, Should reflect "V" for Title V
Regional equivalents of:
ER Compliance Certification EPA Review
SR Compliance Certification State Review
Not Required
Date of Review.
Required by EPA, reports compliance:
MC=Compliance
MV=Violation
MU=Unknown
Not required.
Required by EPA, reports deviations:
Y=Yes
N=No
Or number of deviations may be reported.
Not required
Not required.
Not required
Not required.
18. Tracking Full Compliance Evaluation Pathways in AFS:
AFS has the capability to track individual activities that lead up to the completion of a Full
Compliance Evaluation (FCE) using the same process in place for tracking High Priority
Violators (HPVs). By use of a special FCE Pathway Action Type, the individual components of
the FCE can be documented.
Four new National Action Types have been incorporated into the AFS action tables to allow for
the tracking of FCE components:
5E EPA On-Site FCE Pathway
5F EPA Off-Site FCE Pathway
5G State On-Site FCE Pathway
5H State Off-Site FCE Pathway
Once an FCE Pathway has been established, the user can link related activities leading up to the
completion of an FCE.
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Additionally, the AFS 620 Fixed Report can be used to facilitate tracking:
DATE
AIRS FACILITY SUBSYSTEM
SELECTION CRITERIA
REPORT NAME: AFS PATHWAY SUMMARY REPORT
OPTIONAL TITLE:
CRITERIA NAME:
ENTER 'X' TO SELECT PATHWAYS (*) AND SPECIFY DATA SELECTION VALUES:
* VIOLATION: _ STATE DAY 0 _ FEDERAL DAY 0 _ NON-HPV DAY 0
_ ADDRESSED _ UNADDRESSED _ RESOLVED
VIOLATING POLLUTANTS:
* ADMINISTRATIVE ORDER:
* CONSENT DECREE:
EPA 113(A) ORDER _ STATE ADMIN ORDER
STATE COURT ORDER FEDERAL COURT ORDER
ADMINISTRATIVE PENALTY: _ EPA 113(D) ADMIN COMPLAINT
FULL COMP EVAL: _ EPA ONSITE _ EPA OFFSITE _ STATE ONSITE _ STATE OFFSITE
KEY ACTION DATE ACHIEVED(YYMMDD):
This will generate a report output for use:
DATE L 06/12/06
PIAHT HAHE
STREET ADDSEES
CITY
HE 16
15/77T/B2TS1:1
BETSY'S TEST PLW1T
123 WIM
METCA1F
.Xjrt-tfMT :
AFS PATHHW SU*MY REPOJT - HP1.' FfttUUM
ENFMCEWHT SENSITIVE IATA IHCLUEED
"!"] CQMFMAH "^ FVA'/'A^'CN IT"^' FAT-kftV
STAPF MSW DK1MIHT HUHBER fEY A^IIflW
STATE RESIST LINKED ACTIflHIS)
NLM TYPE DESCBIPTIQN SCHEt
001 OC S/L OMSI7E PATH / /
002 AT OBSERVE PCE -ST / /
003 AH PROCESS PCE -3T / /
004 Alt PCE; OFFSITE- ST / /
ODE SR TV STATE REVIEW / /
006 A3 FCEyOHSITE - 3T / /
VI: AFP620
AC (Ml
'i-'<:*
D6/oeyi2
Bb/Ob./lb
Please keep in mind that use of the FCE pathway will NOT:
Trigger any FtPV flag generation,
Generate any compliance status values,
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Generate Days Unaddressed or Days Used to Address, as these are not
appropriate for this pathway,
Generate an FCE action type.
19. Reporting Non-Applicability Determinations
Each year Regions are required to provide a schedule of activity to be completed that are used
for reporting of Government Performance and Results Act (GPRA) activities. Regions may
commit to the completion of particular air toxics activities, only to find out that the source
intended for review, evaluation or investigation is actually not subject to the particular program
requirements. The addition of the non-applicability action types provide a way for the Regions
to report Air Toxic or NSR/PSD FCEs, PCEs, and/or investigations at facilities that turned out
not to be subject to the particular MACT subpart or NSR/PSD activity targeted for evaluation or
investigation. For further information on GPRA go to: http://www.whitehouse.gov/omb/mgmt-
gpra/gpl aw2m. html .
The following New National Action types for Federal use are available to reporting non-
applicability determinations:
NA-EPA MACT FCE/PCE Non-Applicability Determination
NM-EPA MACT Non-Applicability Determination for Investigations
NN-EPA NRS/PSD Non-Applicability Determination for Investigations
Non-Applicability actions should be reported as follows:
Situation 1: If an FCE/PCE/Investigation finds that the MACT/NSR/PSD Air Program is
not applicable:
Report the appropriate FCE/PCE/Investigation code to document your work, using an
appropriate air program code (Title V or SIP).
Also enter the appropriate non-applicability action type (NA/NM/NN) to document
non-applicability.
Situation 2: If an FCE/PCE/Investigation finds that a certain subpart is not applicable,
but other MACT subparts are:
Report the appropriate FCE/PCE/Investigation code using the MACT air program
code (M). This documents the FCE/PCE/Investigation work for applicable
MACTs.
Also enter the appropriate non-applicability action type (NA/NM) and note the
non-applicable subpart in the RDE 16 field.
AFS REPORTING: REQUIRED REPORTING-RECAP
AIR PROGRAM CODE(S): Required, use appropriate codes as described
above
ACTION TYPE: Regional equivalents of:
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DATE SCHEDULED:
DATE ACHIEVED:
RESULTS CODE:
PENALTY AMOUNT:
RDE8:
STAFF CODE:
POLLUTANT CODE:
CONTRACTOR ID:
RDE16
NA-EPA MACT FCE/PCE Non-Applicability
Determination
NM-EPA MACT Non-Applicability
Determination for Investigations
NN-EPA NRS/PSD Non-Applicability
Determination for Investigations
And applicable FCE/PCE/Investigation
actions types as described above
Not Required
Date of Activity
Not required.
Not required.
Not required.
Not required
Not required.
Not required
Non-Applicability subpart(s) for actions
NA/NM.
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SECTION 4 SECURITY AND AFS
A. EPA's SECURITY MEASURES FOR AFS
AFS supports EPA, as well as State and local agencies, needing information to carry out air
compliance management programs. All AFS users must ensure that the AFS application and its
data are protected from loss, misuse, and unauthorized access or modification. These security
measures for AFS are intended to protect the air compliance data that State and local agencies
periodically submit to EPA. This protection includes measures to protect against unauthorized
modification or loss of data, while at the same time protecting the underlying computer system
that EPA operates.
There are certain security practices and procedures that should be followed to minimize the
potential misuse or damage to the AFS database. Some of these include:
Be familiar with the security policies and practices involving the AFS
application, especially those for confidential or sensitive information.
Maintain security for the application by correctly using established security
mechanisms (use of unique user ID and password) and practices when accessing
the AFS application.
Do not attempt to view, change, or delete data unless you are authorized to do so.
Do not use your system privileges to obtain data/files or run applications for
anyone who is not authorized to view or use data that are sensitive.
Be alert to potential threats to corrupt or destroy the AFS application and
database.
Ensure that no one person has sole access to, or control over, AFS information
and processing resources.
Guard user ID and password. Do not loan out to others.
For more information on security practices and procedures to protect the database please refer to
Appendix 6: Security and AFS
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B. AFS CONTINGENCY PLANNING - WHAT TO DO IN A DISASTER
AFS Contingency Planning
Standard Operating Procedures
Background
The purpose of the AFS contingency plan is to ensure that AFS data is available in the event of a
disaster. The AFS is critical to performing a primary EPA mission which is to support the air
compliance/enforcement program. As a result, the AFS must be available within 15-30 days
following a catastrophic disaster to avoid impairment of EPA's long-term ability to accomplish
its mission.
Introduction
This standard operating procedures (SOP) document was compiled to provide guidance to AFS
users on the steps necessary to support a continuity of operations in the event of a disruption
resulting in the inaccessibility of the AFS.
Disruptions Affecting AFS
An emergency affecting the accessibility of AFS can vary from being a temporary disruption that
is quickly rectified with minimal impact, to a catastrophic disruption resulting in great amounts
of time where AFS is not available. Different types of disruptions fall within the following
categories:
Category
Temporary Disruption
Major Disruption
Catastrophic
Disruption
Length of Time AFS is
Unavailable
3 working days or less
3-14 working days
>15 working days
Example Cause
Minor software failure due to
improper installation
S oftware/hardware
malfunctions, Malfunction to
NCC support due to severe
inclement weather
Complete failure of support
due to security breach,
communication failure
Standard Operating Procedures
For disruptions lasting less than 15 days, you will need to input your data immediately when you
have been informed that the AFS is back in operation and accessible. However, for disruptions
that are 15 days and greater, there are 5 steps that you should take to implement contingency
planning:
Step 1: Notify the Appropriate Personnel
If you notice that the AFS is not available when you attempt to log on please contact someone
immediately. Please see Section 8: AFS Contacts for a listing of key persons that you should
contact.
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Step 2: Check Information Sources for Updates
Refer to the available information sources for updates to know the status of the disruption. You
should check:
1. Your phone and/or email
2. AFS Helpline
3. AFS Mainframe Bulletin Board - assuming you were able to finally log in
4. AFS Regional Compliance Manager
5. AFS Website
Step 3: Document Your Agency's AFS Data
Independent of whether or not AFS is accessible, data must be collected according to the latest
issuance of the AFS Information Collection Request. Be sure to label sensitive data
appropriately.
>Batch users, including Universal Interface users, will continue to create batch update
files as usual. Batch users of AFS will be asked to hold future submittals until NCC is
restored or an alternative reporting platform is supplied. Batch users may also be asked to
generate activity reports from their own systems to ensure a flow of information to the
EPA Regional and Headquarters offices.
>Direct users of AFS will be requested to maintain records of activity defined as
reportable to AFS. These data elements are defined by the minimum data requirements as
listed in the AFS Information Collection Request (ICR) which was approved by the
Office of Management and Budget. Direct users will enter their data into the AFS
Contingency Planning Worksheet spreadsheets (Appendix 10: AFS Contingency
Planning Data Entry Form), either electronically or hardcopy format.
Step 4: Submit Data to EPA at Scheduled Intervals
Data should be submitted to your Regional AFS Compliance Managers at scheduled intervals.
Those intervals must fall within the 60 day time frame as specified in the AFS ICR. For further
clarification and guidance on the types of data to be submitted, please refer to the Clean Air Act
Federally Reportable Violation Clarification document and the AFS Information collection
Request Minimum Data Requirements document. States and local agencies should submit their
data to EPA headquarters and copy their Regional Compliance Manager. Data submissions
should be submitted via email. However, if the email system is unavailable, data submissions
should be sent via postal mail. Please review the checklist below for a listing of the data
elements that must be included in the submission to your Regional AFS Compliance Manager
and to EPA HQ.
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Data Element Submission Checklist
Plant General Record: New Plants or
Changes to Existing Plant Records
Q AFS ID
QName
Q Street
QCity
Q County
Q State
QZip
QSICorNAICS
Q Government Use Code
Q Applicable Air Programs
Q Air Program Operating
Status
Q All Applicable Subparts
Q Air Program Pollutants
Q Air Program Pollutants
w/ Classification
Q Compliance Status
Q Attainment /
Nonattainment Indicator
HPV Information
Pathways Should be Tracked with:
Q Discovery Date
Q Day Zero
Q Date Addressed
Q Date Resolved
Q Violation Type
Q Violating Pollutants
Actions Reportable Under '07 ICR
Q Full Compliance Evaluations
Q Stack Tests
Q Annual Title V Compliance
Certifications
Q Investigations
Q Notices of Violation
Q Formal Enforcement Actions
including Consent Decrees
Q Administrative Orders
Q Civil Referrals
Q Criminal Referrals
Actions Should Include:
Q Applicable Air Programs
Q Action Types
Q Date Achieved
Q Date Scheduled
Q RDE8 field
Q Penalties
Q Results Code
Compliance Monitoring Information
Q Update to CMS plan as needed
The following activity reports may also be requested:
Number of Full Compliance Evaluations completed during a specified time frame.
Number of Stack Tests observed or reviewed during a specified time frame.
Number of Notices of Violation completed during a specified time frame.
Number of Enforcement Actions taken during a specified time frame.
Specified HPV activity during a specified time frame.
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AFS BUSINESS RULES COMPENDIUM
Step 5: Resume Normal Operations upon Notification that the System has been Rectified
AFS does not subscribe to the NCC Disaster Recovery Planning service and as a result the AFS
will assume restoration of services as soon as is possible for NCC support to restore the system
and its functions. Upon notification that AFS is functional, the respective state/local agency is
required to submit their batch input files into the AFS system. To avoid accidental duplicate data
entry, the state/local agency should inform their Regional AFS Compliance Manager about their
data submittal to AFS.
C. GUIDELINES FOR HANDLING ENFORCEMENT SENSITIVE DATA
It is paramount that any sensitive information (e.g., enforcement sensitive data) in the AFS
application is protected from unauthorized access. Data that has been identified as enforcement
sensitive includes:
National
Action
Type
C2
El
SI
UB
UC
US
1D
1E
3D
4B
4F
4H
4J
4L
Description
1 1 3D APO recalculated
EPA Investigation Initiated
State Investigation Initiated
11 3D Unmitigated Economic Benefit (OBSOLETE)
11 3D Unmitigated Gravity Comp. (OBSOLETE)
11 3D Total Unmitigated Penalty (OBSOLETE)
State Criminal Referral
Civil Referral to State AG
State Civil Penalty Assessed
EPA Civil Referral
Civil Referral Notification (OBSOLETE)
Civil Referral Notification Deficiency by State (OBSOLETE)
Civil Referral Substantive Violation by EPA (OBSOLETE)
Civil Referral Substantive Violation by State (OBSOLETE)
Keep in mind the following:
Be sure to provide only authorized personnel with sensitive data (whether the
data are on your screen, on paper or in an electronic file).
When viewing or processing confidential or sensitive data, be sure the PC is
in a non-traffic area and that only persons authorized to see the data are in
the area.
Protect all documents, reports and files containing sensitive data. Be sure
that they are labeled "ENFORCEMENT-SENSITIVE."
Destroy sensitive documents by shredding when finished with them.
Safeguard sensitive data. Do not store to your hard drive, safeguard your
diskettes.
Log off your computer when you are away from your work station!
Lock up or put away sensitive data.
AFS Business Rules Compendium Revision 4.1 August 2009
Page 67 of 76
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AFS BUSINESS RULES COMPENDIUM
SECTION 5 NATIONAL INITIATIVES
A. AIR TOXICS INITIATIVE
In February 2008, the Air Toxics Strategy Implementation Team approved the National Air
Toxics Compliance and Enforcement Priority strategy. Tracking of this initiative will be
dependent upon the accuracy of the data in AFS for Federal activities. The goal of the Air
Toxics National Compliance and Enforcement Priority (FY08-10 Strategy) is for each EPA
region to address eighty percent of the facilities in the regional selected MACT standard(s)
within the National Problem Areas. The MACT Prioritization Tool on the OTIS web page will
contain a page with the current status of completion for each Region. Data to populate this page
will be extracted from AFS.
The National Problem Areas have been defined as Leak Detection and Repair (LDAR),
industrial flares, and surface coating. Please see the attached table of applicable MACT
subparts. Addressing is defined as:
ปปป Determining through a partial or full compliance evaluation (PCE/FCE) that the facility is
not subject to the selected MACT,
*ป* Determining through an PCE or FCE that no further action is needed at this time,
ปปป Determining through an Investigation that no further action is needed at this time,
ปปป Issuing an administrative order or administrative penalty order,
ปปป Referring a case to the Department of Justice (DOJ).
To track this priority in AFS, EPA regions will have to provide the following information:
1. Source Universe Identification: Identification of an Air Toxics source universe that can
be retrieved from AFS. Field AMBM on the Plant General record will be used to identify
sources within this initiative.
2. Appropriate Subpart Identification.
3. Unique action types to identify air toxics initiatives.
4. Identification in an action record to identify if no further action is needed.
Specific Data Requirements:
1. Source Universe Identification: The Air Toxics source universe identification shall be
maintained via the use of the AMBM code on the Plant General record. This field, previously
used to document ambient monitoring, will be renamed "Air Toxic Initiative". It is a one-digit
alpha-numeric field where each Region will identify the appropriate Air Toxics source universe.
A national code table has been created based on the initiatives that have been chosen by the
regions and is available in AFS utilities.
2. Appropriate Subparts: Sources subject to the initiative should have the appropriate subpart
entered on the MACT air program record:
Surface Coating MACTs
AFS Business Rules Compendium Revision 4.1 August 2009 Page 68 of 76
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AFS BUSINESS RULES COMPENDIUM
Auto and Light Duty Truck (IIII)
Fabric, Printing, Coating and Dying (OOOO)
Large Appliances (NNNN)
Magnetic Tape (EE)
Metal Can (KKKK)
Metal Coil (SSSS)
Metal Furniture (RRRR)
Misc. Metal Parts and Products (MMMM)
Paper and Other Web (JJJJ)
Plastic Parts (PPPP)
Printing and Publishing (KK)
Shipbuilding and Ship Repair (II)
Wood Building Products (QQQQ)
Wood Furniture (JJ)
LDAR/Flare MACTs
Flexible Polyurethane Foam (III)
Gas Distribution (R)
Generic MACT (YY)
HON (H)
MON (FFFF)
Marine Vessal Loading (Y)
Misc. Coating Manufacturing (HHHHH)
Municipal Waste Landfill (AAAA)
Natural Gas Transmission and Storage (HUH)
Oil and Gas Production (HH)
Pesticide Active Ingredient (MMM)
Petroleum Refineries (CC)
Pharmaceutical (GGG)
Organic Liquids Distribution (EEEE)
Polymer and Resins, Group IV (JJJ)
3. Unique Action Data Entry: In order to identify activities that are part of this initiative, special
action types will be created for the following activities and mapped to the appropriate National
Action Types:
Action
Type Description Equivalent To:
AA FEDERAL AIR TOXICSONSITEFCE FE
AB FEDERAL AIR TOXICS OFFSITE FCE FZ
AC FEDERAL AIR TOXICS ONSITE PCE ES
AD FEDERAL AIR TOXICS OFFSITE PCE EX
AE FEDERAL AIR TOXICS INVESTIGATION INITIATED El
AFS Business Rules Compendium Revision 4.1 August 2009 Page 69 of 76
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AFS BUSINESS RULES COMPENDIUM
AF FEDERAL AIR TOXICS INVESTIGATION COMPLETED EC
AG FEDERAL AIR TOXICS ADMINISTRATIVE ORDER 8A
AH FEDERAL ADMINISTRATIVE PENALTY ORDER 7F
AI FEDERAL AIR TOXICS REFERRAL TO DOJ 4B
AJ NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS NA
All Regions are asked to map equivalent actions into their action tables. Regions that have
already entered data into AFS for FY08 that are applicable to this initiative will need to change
the action type in the existing action record.
4. Results Code: In order to identify if no further action is needed, a unique results code will be
needed in each Air Toxics Initiative action record (RSC1). When an FCE, PCE, or Investigation
is completed and no further action is required (no enforcement action will be pursued), then a
Results Code will provide the information needed to address the source within the initiative.
Results
Code Description
AN NO FURTHER ACTION REQUIRED
B. OTHER NATIONAL INITIATIVES:
There is occasionally the need to identify work not consistent with air program definitions.
National programs to track PSD/NSR review, Air Toxics, area sources and others requires the
ability to identify several different kinds of sources in a unique manner to facilitate reporting and
data analysis. Work is underway to create fields within AFS to supersede the use of the AMBM
field currently used for the national Air Toxics Initiative and allow application of multiple
national initiative universes. This effort is underway and not immediately available within AFS.
New fields will be created at the Plant General and Action Records in order to identify the
sources involved in different initiatives and applicable actions. Work is expected to be
completed by FY2010.
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AFS BUSINESS RULES COMPENDIUM
SECTION 6 SUGGESTIONS FOR IMPROVING AFS
During the period of Business Rules compilation (Fiscal Years 03 and 04), several
recommendations were made concerning the improvement of AFS:
Many agencies track compliance status by source, not by air program pollutant. Requests
to discontinue tracking at the air program pollutant level have been submitted not only
during the Business Rules process, but during the AFS Needs Analysis completed in
FY02. The air program requires the identification of the pollutant in violation, but an
effort to streamline data reporting is being included in modernization efforts.
o UPDATE: The compliance monitoring and enforcement program for the
oversight of CAA stationary sources requires a compliance status based on
pollutant regulations. The EPA Regional Air Enforcement Managers have agreed
to allow the modernized system to track noncompliance by pollutant, but not
require a listing of pollutants by air program. This is expected to significantly
streamline data entry.
Many agencies do not agree that compliance status should be tracked by disposition of
enforcement activity. It was reported during conference calls that many agencies
consider physical compliance a more reliable way to track compliance with the Act.
Sources with unresolved High Priority Violator cases physically in compliance with the
Act will be listed as "Meeting Schedule" or "In Violation" until all injunctive reliefer
penalties are paid. An AFS Workgroup to study Compliance Status has been formed
with an expected output in late FY04/early FY05.
o UPDATE: Although a workgroup was formed to study this issue, no clear
findings were compiled. Violators will be listed in violation with regulations until
all requirements for compliance are met. The modernization of AFS will
introduce additional fields where reporters can indicate that a facility is meeting
all pollutant requirements, but might have outstanding enforcement
responsibilities such as penalties, equipment installation schedules, or other
injunctive relief.
Many agencies are reporting a Notice of Violation with a proposed penalty, or stipulated
penalty. These actions are being counted as a Notice of Violation, but should also be
reported as an Administrative Order with Penalty. This compendium advises that any
NOV with penalty be reported as two separate actions: an NOV and an Administrative
Order.
o UPDATE: AFS has provided guidance and training in this area, along with
presentations at the FY06 and FY07 National AFS Workshops requiring
appropriate reporting for this enforcement situation.
Guidance has been requested for the reporting of Civil Actions by both Federal and State
users of AFS. Action types defined as "Civil Action" for filing a complaint are being
used to report settlements. New action types for state or district filings have been
requested. An AFS Workgroup to study Enforcement Actions has been formed with an
AFS Business Rules Compendium Revision 4.1 August 2009 Page 71 of 76
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AFS BUSINESS RULES COMPENDIUM
expected output in late FY04/early FY05. In addition, this group will study the reporting
of penalty data and reporting information on appealed enforcement cases.
o UPDATE: Optional enforcement actions for state use were entered into AFS.
The tracking of appealed cases has been set aside for action during the design
phase of a new system. The creation of fields necessary to track this information
is too cost prohibitive for current AFS.
ปปป Penalty data is not being reported consistently across the country. Values from injunctive
relief and Supplemental Environmental Projects are being added to the penalty field,
which is designed to reflect assessed cash penalties only. In cases of court decisions
affecting multiple locations, policy for distribution of penalty has been requested.
Additionally, penalty amounts are not being reported on the official enforcement action,
and are being reported under an action type "Penalty Paid", thus not captured in RECAP
analyses.
o UPDATE: Data quality activities have been put into place to review reported
penalties. The new acronym AAPA-Addressing Action Penalty Amount,
provides a retrievable field for identifying penalties in HPV cases, to facilitate
review of data.
ปปป Guidance is needed for the reporting of appealed cases, where changes in the final
penalty have been made.
o UPDATE: This category of enforcement reporting has been set aside for action
during the design of a new system. The creation of fields necessary to track this
information is too cost prohibitive for current AFS.
ปปป There are areas where the appropriate air program codes are not being reported.
Specifically, Title V applicability, New Source Review (NSR) and Prevention of
Significant Deterioration (PSD) air programs are not being identified. The correct
reporting of air program codes should be a priority of Regional AFS Compliance
Managers for data accuracy.
o UPDATE: All Regional AFS Compliance Managers are responsible for the
accuracy of the air program code universe in their delegated region.
ปปป One Region asked for the ability to track emission credits and trading.
o UPDATE: This category of enforcement reporting has been set aside for action
during the design of a new system. The creation of fields necessary to track this
information is too cost prohibitive for current AFS.
*ป* One Region asked for stack test results (Pass or Fail) to be written into AFS code making
the information mandatory for reporting on the action type. This type of functionality is
being considered in ongoing modernization efforts.
o UPDATE: Stack Test Pass/Fail/Pending codes are reportable MDRs to AFS.
Additional programming can be reviewed during the design phase of
modernization.
ปปป One Region has asked for recommended procedures for change of ownership-issues of
culpability have been raised and at least one local agency refuses to saddle a new owner
with the compliance history of past ownership.
AFS Business Rules Compendium Revision 4.1 August 2009 Page 72 of 76
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AFS BUSINESS RULES COMPENDIUM
o UPDATE: AFS is a system reporting on the CAA management at stationary
sources. The definition of a stationary source is anything within the facility fence
lines. Ownership may change, but land use and previous problems are inherited
with the facility.
Guidance has been requested for reporting of stack test failures.
o UPDATE: Stack Test Guidance was compiled in 2005 and an update to the
guidance is scheduled for release in 2009.
AFS Business Rules Compendium Revision 4.1 August 2009 Page 73 of 76
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AFS BUSINESS RULES COMPENDIUM
SECTION 7 AFS DOCUMENTATION
Current documentation used for reporting data to AFS:
Document Name/Web Site
Compliance Monitoring Strategy AFS Technical Support Document
http://www.epa.gov/compliance/resources/publications/data/systems/air/cmstechman.pdf
The Timely & Appropriate Response to High Priority Violators
http://www.epa.gov/compliance/resources/policies/civil/caa/stationary/hpvmanualrevised.pdf
AFS National Action Types
http://www.epa.gov/compliance/resources/publications/data/systems/air/actions.pdf
List of Minimum Data Requirements (MDRs)
http://www.epa.gov/compliance/resources/publications/data/systems/air/mdrshort.pdf
AF1: Data Dictionary
http://www.epa.gov/compliance/resources/publications/data/systems/air/afl.pdf
AF2 Data Coding Manual
http://www.epa.gov/compliance/resources/publications/data/systems/air/af2.pdf
AFS Data Storage Manual
http://www.epa.gov/compliance/resources/publications/data/systems/air/af3.pdf
AFS Data Acronym Guides
http://www.epa.gov/compliance/resources/publications/data/svstems/air/acronymacroname.pdf
http://www.epa.gov/compliance/resources/publications/data/svstems/air/acronymfilename.pdf
AFS Universal Interface Operators Manual
AFS Business Rules Compendium Revision 4.1 August 2009 Page 74 of 76
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AFS BUSINESS RULES COMPENDIUM
SECTIONS AFS CONTACTS
Ms. Akachi Imegwu
AFS Security Manager
1201 Pennsylvania Ave, NW
Washington DC, 20460
Direct Phone (202) 564 - 0045
Main Phone: (202) 272 - 0167
Toll Free: 1-866-411-4372
Fax (202) 564 - 0032
imegwu. akachitgiepa. gov
afs-support@epa. gov
AFS Website:
Region 1
Ms. Beth Kudarauskas
1 Congress St. Suite 1100
Boston, MA 02114-2023
Direct Phone: (617) 918-1564
Fax (617) 918-0564
Toll free w/inRl: (888) 372-7341
Main Phone:(617)918-1111
kudarauskas.beth(@,epa.gov
Region 3
Ms. Louvinia Madison-Glenn
1650 Arch Street
Philadelphia, PA 19103-2029
Direct Phone: (215)814-5704
Fax (215) 814-2134
Main Phone: (215) 814-5000
Toll free: (800) 438-2474
madison. louvinia(@,epa. gov
Region 6
Ms. Pam Elder-Schweers
Fountain Place 12th Floor
1445 Ross Avenue
Dallas, TX 75202-273 3
Direct Phone: (214) 665-7463
Fax (214) 665-7446
Main Phone: (214) 665-2210
Toll free w/inR6: (800) 887-6063
elder-schweers.pam@,epa. gov
Region 8
Mr. Jeff Mo sal
1595 Wynkoop St.
Denver, CO 80202-1129
Direct Phone (303) 312 - 6802
Main Phone: (303) 312-6312
Toll free: (800) 227-8917
mosal.jeffrey(@,epa. gov
Region 10
Ms. Laurie Krai
TRC Environmental
Contract Support Team
Helpline: 800-367-1044
Afshelpline@,trcsolutions.com
AFS CONTACTS
Ms. Betsy Metcalf
AFS Systems Administrator
1201 Pennsylvania Ave, NW
Washington DC, 20460
Direct Phone (202) 564 - 5962
Main Phone: (202) 272 - 0167
Toll Free: 1-866-411-4372
Fax (202) 564 - 0032
metcalf.betsv(g),epa. gov
afs-support(g),epa. gov
http://www.epa.gov/compliance/contact/data-afscontacts.html
Region 2
Mr. Phillip Ritz
290 Broadway
New York, NY 10007-1866
Direct Phone (212) 637-4064
Fax (212) 637-3998
Main Phone: (212) 637-3000
ritz.phillip(g),epa. gov
Region 4
Mr. Ahmed Amanulah
Atlanta Federal Center
6 IForsyth Street, SW
Atlanta, GA 30303-3104
Direct Phone (404) 562-9209
Fax (404) 582-9164
Main Phone: (404) 562-9900
Toll free: (800) 241-1754
amanulah.ahmed@,epa. gov
Region 7
Mr. Hugh "Joe" McCullough
901 North 5th Street
Kansas City, KS 66101
Direct Phone (913) 551 - 7191
MainPhone: (913) 551-7003
Toll free: (800) 223-0425
Mccullough.hugh(@.epa. gov
Region 9
Ms. Linda Barajas-Porter
75 Hawthorne Street
San Francisco, CA 94105
Direct Phone (415) 947-4131
Fax (415) 947-3579
MainPhone: (415) 947-8000
Toll free w/in R9: (866) EPA-WEST
baraias-porter.linda(@,epa. gov
Region 2
Mr. Steve Carrea
290 Broadway
New York, NY 10007-1866
Direct Phone (212)637-3498
Fax (212)637-3998
MainPhone: (212) 637-3000
carrea.steve(g),epa.gov
Region 5
Ms. Lisa Holscher
77 West Jackson Boulevard
Chicago, IL 60604-3507
Direct Phone (312) 886-6818
Fax (312) 353-8289
MainPhone: (312) 353-2000
Toll free w/in R5: (800) 621-8431
holscher. lisa@,epa. gov
Region 8
Ms. Jocelyn Hoffman
1595 Wynkoop St.
Denver, CO 80202-1129
Direct Phone (303) 312 - 6232
MainPhone: (303) 312-6312
Toll free: (800) 227-8917
Hoffman.iocelvn(@,epa.gov
Region 9
Mr. John Borton
75 Hawthorne Street
San Francisco, CA 94105
Direct Phone (415) 972-3985
Fax (415) 947-3579
MainPhone: (415) 947-8000
Toll free w/in R9: (866) EPA-WEST
borton.iohn(@,epa.gov
AFS Business Rules Compendium Revision 4.1 August 2009
Page 75 of 76
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AFS BUSINESS RULES COMPENDIUM
1200 Sixth Avenue, Suite 900
Seattle, WA 98101
Direct Phone (206) 553-1868
Fax (206)553-0110
Main Phone: (206) 553-1200
Toll free: (800) 424-4372
kral.laurie(@,epa. gov
AFS Business Rules Compendium Revision 4.1 August 2009 Page 76 of 76
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.<*
AFS BUSINESS RULES
COMPENDIUM
APPENDICES
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-------
Appendix 1
Compliance Monitoring Strategy Charts
-------
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12/16/08
Generate Unknown Compliance Status Utility
STEP1: Determine if the
plant is part of the CMS
E|Se->
Exit utility
STEP 2: Determine the current
default compliance status of the Facility
Else-*
STEP 3: If CMSI
-Then->
Then-)
Either
CMSC=OorZ
or
CMSI is equal to or greater
than the recommended
minimum frequencies
Then-*
-Then.*
STEP 4: Generate oldest possible
FCE date (BASELINE)
Subtract CMSI from the
current date giving the
FCE BASELINE date
(convert to FY)
-Then-* g,
3 to
sp 5
STEP 6: Generate FY for
Default Date of Latest FCE
(ACTUAL)
Generate FY
for DFD1
-Then-* ^
)to
P7
STEP 5: Determine if the CMS start date
keeps the plant in the Utility
Else-*
STEP 7: Is
the ACTUAL FCE past due?
Version 6.0
-------
12/18/07
Generate Unknown Compliance Status Utility
Generate
SIP air program (0)
air program status = O
Generate
ECAP=U
Generate
ECLP=A
Update the
record with JH1
& current date
Version 5.0
-------
12/18/07
Generate Unknown Compliance Status Utility
Generate
SIP air program (0)
air program status = O
Version 5.0
-------
APPROVED 11/6/03
Ungenerate Unknown Compliance Status Utility
Update the
record with
JH1 &
current date
THEN-
Has an FCE beerh
performed within the
appropriate CMS
timeframe?
-NO-
EXIT Utility
YES
THEN
THEN-
Update the
record with
JH1 &
current date
-THEN
THEN-
Version 1.3
-------
12/18/07
Effect on CMS Start Date
when CMSC is modified
Description
Blank to anything
Anything to blank
Downgrade to SM80 or Other
Upgrade to Major or Mega
Downgrade to Other
Upgrade to any value
j current value
| CMSC
blank
A, E, M, G, S, N,OorZ
A, E, MorG
SorN
s oFisi
OorZ
new value
CMSC
^^^
blank
_^jysLP^Lz^^
A, E, MorG
Oo'rZ
A,E, M.G.SorN
Effect on
CMS Start Date
change to current date
blank out
dojnotJTing
change to current date
dojnothing
..chang_ejo_cjjrrent_dat_e_
version 5.0
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-------
Appendix 2
AFS Plant General Structure/Data
Element Dictionary
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AFS BUSINESS RULES DATE OF LAST UPDATE:
STRUCTURE-PLANT GENERAL
RECORDS IN BOLD TEXT ARE MINIMUM DATA REQUIREMENTS
03/02/09
DATA ELEMENT NAME
AFS PLANT ID
AFS PLANT IDENTIFICATION NUMBER
AIR PROGRAMS
AIR QUALITY CONTROL REGION
AIR TOXIC INITIATIVE
CDS PLANT ID
CDS PLANT ID 1
CDS PLANT ID 2
CDS PLANT ID 4
CITY CODE
CLASSIFICATION CODE
COMPLIANCE STATUS
CONTACT PERSON COMPLIANCE
CONTACT PERSON EMISSIONS
CONTINUOUS EMISSIONS INDICATOR
COUNTY CODE
COUNTY NAME
DATE DETERMINATION COMPLETED
DATE PLANT ADDED POST-CMS
DATA ELEMENT DEFINITION
A mandatory 15-digit code identifier for permit information
for Permit Program Data Elements (PPDEs). This number
must be unique within a county and requires the FIPS state
and county codes to uniquely identify a plant in AFS.
System generated. An internal number assigned to each
plant in AFS.
System generated. Lists applicable air programs at a plant.
Used in Ad Hoc reporting, lists all air program codes.
A system generated field based on user-supplied plant,
state, and county values identifying the Air Quality Control
Region in which a plant is located.
Federial Use for national initiative
Mandatory 5-digit alphanumeric plant identifier for each
plant in AFS. Uniquely identifies a source within a
county.
This optional use field identifies the left (first) digit of the
PCDS number. It is used in ad hoc retrievals.
This optional use field identifies the left two (first and
second) digits of the PCDS number. It is used in ad hoc
retrievals.
This optional use field identifies the four right most digits of
the PCDS number. It is used in ad hoc retrievals.
Optional use. A 5-digit FIPS city code used to identify the
city in which a plant is located.
System generated code that provides the plant default
classification.
System generated code that provides the plant default
compliance status.
The name of a person who is knowledgeable about the
compliance information for the facility.
OBSOLETE
A system generated field when records associated with
Continuous Emissions Monitoring information are added or
deleted for the plant. Valid value is Y=Yes.
Mandatory FIPS code used to identify the county in
which a plant is located.
System generated field which identifies the county in which
a plant is located.
OBSOLETE
A system generated field designed to maintain the date a
plant has been added to AFS after the inception of the CMS.
This field is used in calculations dealing with unknown
compliance status.
ACROYNM
PAFS
PLNT
APCP
AQCR
AMBM
PCDS
PCD1
PCD2
PCD4
CYCD
CLAS
CMST
CTPC
CTPE
CEM1
CNTY
CTNM
MACD
DPAC
TYPE
A
A/N
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
WIDTH
15.0
9.0
8.0
3.0
1.0
5.0
1.0
2.0
4.0
5.0
5.0
5.0
20.0
20.0
1.0
3.0
30.0
8.0 50
6.0
COMMENT
Most agencies use the SCSC acroynm
number for populating PAFS
(SSCCCPPPPP where S=FIPS State,
C=FIPS County, and P=PCDS ID).
Was used in the ENVIROFACTS system
to identify AFS linkages.
Most agencies number plants within a
county sequentially as they are added
to AFS.
Some agencies use this acroynm to
categorize plants.
Some agencies use this acroynm to
categorize plants.
Some agencies use this acroynm to
categorize plants.
Entry of either the City Code or City
Name is mandatory. Reference the FIPS
table in AFS Table File Lookup in the
Utilities.
CEM data is not part of the MDRs.
Reference the FIPS table in AFS Table
File Lookup in the Utilities.
Reference the FIPS table in AFS Table
File Lookup in the Utilities.
EPA DATA
STANDARD
MDR?
N
N
N
N
Y
N
N
N
N
N
N
N
OBSOLETE
N
Y
N
OBSOLETE
N
PAGE 1 OF 7
PLANT GENERAL
-------
DATA ELEMENT NAME
DATE PLANT INFO LAST UPDATED
DATE RECORD IS UPDATED
DUN BRADSTREET NUMBER
E S CLASSIFICATION CODE
E S CLASSIFICATION CODE DESC
E S COMPLIANCE STATUS
E S COMPLIANCE STATUS DESC
EMERGENCY CONTROL PLAN
EMERGENCY CONTROL PLAN DESC
DATA ELEMENT DEFINITION
System generated field containing the most current date on
which changes were made to any record on the plant.
System generated field containing the most current date on
which changes were made to the Plant General record.
Optional information, this identification number references
the source within the Dun and Bradstreet business
database. Update access to this field is limited to system
administrators.
System generated default classification. This value is
generated from the Air Program Pollutant values to reflect
the highest emission level classification of criteria pollutants
regulated by an air program. This value is generated
regardless of Federal or State/Local agency values. Valid
Values are: A=Major, SM=Synthetic Minor, B=Minor,
C=Unknown.
System generated default classification. This description of
the classification code is generated from the Air Program
Pollutant values to reflect the highest emission level
classification of criteria pollutants regulated by an air
program. This value is generated regardless of Federal or
State/Local agency values. Valid Values are: A=Major,
SM=Synthetic Minor, B=Minor, C=Unknown.
A system generated default bubble-up value of the most
serious compliance status of air program pollutants at a
plant. The most serious case (worst to best) is bubbled-up
from either the state or federal value. Compliance values
fall within 4 categories: In Compliance, Out of Compliance,
On Schedule, and Unknown Compliance. Sources with
unaddressed High Priority Violations should be listed as Out
of Compliance. Title V Annual Compliance Certifications
with deviations may or may not be listed as Out of
Compliance. See Air Program pollutants for individual
values. See the Data Dictionary for all valid values.
A system generated description of the default bubble-up
value of the most serious compliance status of air program
pollutants at a plant. The most serious case (worst to best)
is bubbled-up from either the state or federal value.
Compliance values fall within 4 categories: In Compliance,
Out of Compliance, On Schedule, and Unknown
Compliance. Sources with unaddressed High Priority
Violations should be listed as Out of Compliance. Title V
Annual Compliance Certifications with deviations may or
may not be listed as Out of Compliance. See Air Program
pollutants for individual values. See the Data Dictionary for
all valid values.
OBSOLETE
OBSOLETE
ACROYNM
DTUP
DU11
DBNO
DCL1
DLD1
DCS1
DDS1
EMCP
EMCD
TYPE
A
A
A
A
A
A
A
A
A
WIDTH
6.0
6.0
9.0
2.0
25.0
1.0
25.0
1.0
25.0
COMMENT
Dun and Bradstreet numbers are not
currently up to date in AFS.
See the Air Program Pollutant records.
Values A1 and A2 are obsolete.
ECHO interprets a source with a
compliance status of On Schedule as in
violation.
EPA DATA
STANDARD
MDR?
N
N
N
N
N
N
N
OBSOLETE
OBSOLETE
PAGE 2 OF 7
PLANT GENERAL
-------
DATA ELEMENT NAME
EPA CLASSIFICATION CODE
EPA CLASSIFICATION CODE DESC
EPA COMPLIANCE STATUS
EPA COMPLIANCE STATUS DESC
EPA PLANT IDENTIFICATION NUMBER
FACILITY CAPACITY
FACILITY CAPACITY UNITS
DATA ELEMENT DEFINITION
System generated Federal classification. This value is
generated from the Air Program Pollutant values to reflect
the highest emission level classification of criteria pollutants
regulated by an air program. This value is generated from
Federal values. Valid Values are: A=Major, SM=Synthetic
Minor, B=Minor, C=Unknown.
System generated Federal classification. This description
of the classification code is generated from the Air Program
Pollutant values to reflect the highest emission level
classification of criteria pollutants regulated by an air
program. This value is generated from Federal values.
Valid Values are: A=Major, SM=Synthetic Minor, B=Minor,
C=Unknown.
A system generated Federal bubble-up value of the most
serious compliance status of air program pollutants at a
plant. The most serious case (worst to best) is bubbled-up
from the Federal value. Compliance values fall within 4
categories: In Compliance, Out of Compliance, On
Schedule, and Unknown Compliance. Sources with
unaddressed High Priority Violations should be listed as Out
of Compliance. Title V Annual Compliance Certifications
with deviations may or may not be listed as Out of
Compliance. See Air Program pollutants for individual
values. See the Data Dictionary for all valid values.
A system generated description of the Federal bubble-up
value of the most serious compliance status of air program
pollutants at a plant. The most serious case (worst to best)
is bubbled-up from the Federal value. Compliance values
fall within 4 categories: In Compliance, Out of Compliance,
On Schedule, and Unknown Compliance. Sources with
unaddressed High Priority Violations should be listed as Out
of Compliance. Title V Annual Compliance Certifications
with deviations may or may not be listed as Out of
Compliance. See Air Program pollutants for individual
values. See the Data Dictionary for all valid values.
A 12-digit number assigned by the Federal Registry System,
used by all EPA systems to identify a plant.
OBSOLETE
OBSOLETE
ACROYNM
ECL1
ELD1
ECS1
EDS1
PEPA
FCAP
FCPU
TYPE
A
A
A
A
A/N
N
A
WIDTH
2.0
25.0
1.0
25.0
12.0
7.0
15.0
COMMENT
Input by EPA staff only. Special User
Profile code R is required. Batch
changes are completed by the AFS
National Contractors.
EPA DATA
STANDARD
Facility
MDR?
N
N
N
N
N
OBSOLETE
OBSOLETE
PAGE 3 OF 7
PLANT GENERAL
-------
DATA ELEMENT NAME
GOVERNMENTAL FACILITY CODE
GOVT FACILITY CODE DESC
INSPECTOR
INSPECTOR NAME
INSPECTOR TITLE
LATITUDE COORDINATE
LOCAL CONTROL REGION
LONGITUDE COORDINATE
MACT CATEGORY
MACT CATEGORY DESC
MACT IDENTIFIER
NAICS CODE
NAICS CODE & EQUIVALENT SICs
DATA ELEMENT DEFINITION
A mandatory field identifying facilities owned or
operated by a governmental unit. Valid values are:
0=AII other facilities not owned or operated by a
Federal, state, or local government; 1=Source owned or
operated by the Federal Government; 2=Source owned
or operated by the State; 3=Source owned or operated
by the County; 4=Source owned or operated by the
Municipality; 5=Source owned or operated by the
District
A system generated description of the Governmental Facility
Code identifying facilities owned or operated by a
governmental unit. Valid values are: 0=AII other facilities
not owned or operated by a Federal, state, or local
government; 1=Source owned or operated by the Federal
Government; 2=Source owned or operated by the State;
3=Source owned or operated by the County; 4=Source
owned or operated by the Municipality; 5=Source owned or
operated by the District.
Optional code to identify a staff member who performed a
plant inspection. This code must be a valid value on the
Staff Table.
System generated optional value, the name of the staff
member who performed a plant inspection. This name is
generated from a code value on the Staff Table.
Optional code to identify the title of a staff member who
performed a plant inspection. The staff code must be a
valid value on the Staff Table.
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
A mandatory code identifying the value of the North
American Industrial Classification System (NAICS).
Either a NAICS or SIC code is mandatory.
System generated value for ad hoc reporting. Use of this
acroynm will produce equivalent SIC codes in a retrieval.
ACROYNM
GOVT
GOVD
INSR
INNM
I NTT
LAT1
LCON
LON1
MACC
MCCD
MACI
NIC1
NICS
TYPE
A
A
A
A
A
N
A
N
A
A
A
A
A
WIDTH
1.0
25.0
3.0
15.0
15.0
6.0
2.0
7.0
4.0
60.0
8.0
6.0
6.0
COMMENT
A valid staff code must be on record in
the Staff Table. Access to the Staff Table
is limited by special authority on the user
profile form.
A valid staff code must be on record in
the Staff Table. Access to the Staff Table
is limited by special authority on the user
profile form. It is recommended that
inspector names be entered with the last
name first, followed by a comma and
then first initial or first name, as space
allows.
A valid staff code must be on record in
the Staff Table. Access to the Staff Table
is limited by special authority on the user
profile form. As the Staff Table is a
Region-specific table, it is recommended
that inspector titles start with the
appropriate agency abbreviation for
distinction.
Either a SIC or NAICS code is
mandatory in AFS to establish a plant.
EPA DATA
STANDARD
MDR?
Y
N
N
N
N
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
Y
N
PAGE 4 OF 7
PLANT GENERAL
-------
DATA ELEMENT NAME
NAICS CODE DESCRIPTION
NEDS PLANT ID
NUMBER OF EMPLOYEES
OPERATING STATUS
OPERATING STATUS DESCRIPTION
PERSON UPDATING RECORD
PLANT CITY
PLANT DESCRIPTION
PLANT NAME
PLANT STREET ADDRESS
PLANT UTM HORIZONTAL COORDINATE
PLANT UTM VERTICAL COORDINATE
PRIMARY INDUSTRIAL CLASS CODE
PRIMARY SIC DESCRIPTION
PRINCIPAL PRODUCT
PRIORITY CODE
PRIORITY CODE DESCRIPTION
PROPERTY AREA
DATA ELEMENT DEFINITION
System generated value of the North American Industrial
Classification System. Either a NAICS or SIC code is
mandatory.
OBSOLETE
OBSOLETE
A one-digit mandatory code identifying the operation
condition of a plant. This value is bubbled-up from the plant
air program records of AFS and is the most significant
operative value of the plant operating status. Valid values
are: O=Operating, L=Landfill, R=NESHAP Renovation,
D=NESHAP Demolition, S=NESHAP Spraying, l=Seasonal,
T= Temporarily Closed, C=Under Construction, P=Planned
Facility, X=Permanently Closed. The order of most
significant to least (for bubble up purposes): O, L, R, D, S, 1,
T, C, P, X.
A system generated bubble-up value of the most significant
operative value of the plant operating status. Reference the
air program operating status.
A system generated value of the User ID last updating the
record.
The name of the city or town where the plant is located.
If a City Code is entered for a plant, the city name will
be generated for valid codes.
An optional use field that allows the user to provide a short
description of plant operations.
A mandatory field which is the name associated with a
plant at a given location. The name should identify the
owning corporation and site name, if applicable. For
example, the Twin Oaks site of an Entergy plant would
be named "Entergy Twin Oaks", not just "Twin Oaks",
or "Enterav".
The street address for the physical location of the plant.
OBSOLETE
OBSOLETE
A mandatory code identifying the primary Standard
Industrial Code (SIC) classifying the main product
produced or service performed at the plant. Reference
the SIC table in the Utilities.
System generated value of the primary SIC description.
OBSOLETE
An optional field. A 1-digit code which is used to identify
facilities falling into various compliance monitoring priority
categories. See the Data Dictionary for valid values.
A system generated field describing the priority code. See
the Data Dictionary for valid values.
OBSOLETE
ACROYNM
NCD1
PNED
NMEP
OPST
OPSD
PU11
CYNM
DSC1
PNME
STRT
UTH1
UTV1
SIC1
SCD1
PRPR
PRIC
PRCD
PRAR
TYPE
A
A
N
A
A
A
A
A
A
A
N
N
A
A
A
A
A
N
WIDTH
75.0
4.0
5.0
1.0
25.0
8.0
30.0
25.0
40.0
30.0
3.1
4.1
4.0
25.0
25.0
1.0
25.0
5.1
COMMENT
Either a SIC or NAICS code is mandatory
in AFS to establish a plant.
Most agencies use the PCDS number
with one less digit for the NEDS ID.
This field does not have state and
Federal values. Operating Status O, T,
and I are used in National RECAP
Retrievals. Operating Statuses L, R, D,
and S are considered obsolete. Sources
Permanently closed for three years or
more should be archived.
This field does not have state and
Federal values.
Entry of either the City Code or City
Name is mandatory. Reference the
FIPS table in AFS Table File Lookup in
the Utilities.
PO Boxes are not allowed in this field.
Also see NAICS acroynms: NIC1,
NICS, NCD1.SICN
Update access to this field is limited to
National EPA personnel. This field is not
currently up to date.
Update access to PRIC is limited to
National EPA personnel. This field is not
currently up to date.
EPA DATA
STANDARD
MDR?
N
OBSOLETE
OBSOLETE
N
N
N
Y
N
Y
Y
OBSOLETE
OBSOLETE
Y
N
OBSOLETE
N
N
OBSOLETE
PAGE 5 OF 7
PLANT GENERAL
-------
DATA ELEMENT NAME
REGION CODE
REGIONAL PLANNING AGENCY
SAROAD STATE CODE
SECONDARY INDUSTRIAL CLASS CODE
SECONDARY SIC DESCRIPTION
SECTION 112 INDICATOR
SECTION 112 INDICATOR DESC
SIC CODE & EQUIVALENT NAICs
SIGNIFICANT VIOLATOR FLAG 1
SIGNIFICANT VIOLATOR FLAG 2
SIGNIFICANT VIOLATOR FLAG 3
SIGNIFICANT VIOLATOR FLAG 4
SIP PROGRAM
SOURCE MONITORING INFORMATION
STATE ABBREV
STATE CLASSIFICATION CODE
STATE CLASSIFICATION CODE DESC
STATE CODE
STATE COMPLIANCE STATUS
DATA ELEMENT DEFINITION
A system generated value identifying the EPA region in
which the plant is located. The code is generated from the
State codes on the AFS FIPS table.
An optional field. User-defined code identifying any
Regional Planning Agency maintaining jurisdiction over the
plant.
OBSOLETE
An optional code identifying the secondary Standard
Industrial Code (SIC) classifying the second most prominent
product produced or service performed at the plant.
System generated value of the secondary SIC description.
OBSOLETE
OBSOLETE
A system generated value for ad hoc retrieval use. Use of
this acronym in a retrieval specifies an SIC code and will
retrieve all equivalent NAICS codes.
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
A two-digit alpha postal abbreviation identifying the state in
which a plant is located. For valid values, see the Data
Dictionary.
System generated default classification. This value is qener;
System generated default classification. This description of
the classification code generated from the Air Program
Pollutant values to reflect the highest emission level
classification of criteria pollutants regulated by an air
program. This value is generated from State/Local agency
values. Valid Values are: A=Major, SM=Synthetic Minor,
B=Minor, C=Unknown.
Mandatory code used to identify the state in which a
plant is located.
A system generated State bubble-up value of the most
serious compliance status of air program pollutants at a
plant. The most serious case (worst to best) is bubbled-up
from the State value. Compliance values fall within 4
categories: In Compliance, Out of Compliance, On
Schedule, and Unknown Compliance. Sources with
unaddressed High Priority Violations should be listed as Out
of Compliance. Title V Annual Compliance Certifications
with deviations may or may not be listed as Out of
Compliance. See Air Program pollutants for individual
values. See the Data Dictionary for all valid values.
ACROYNM
REGN
RPLA
SSTT
SIC2
SCD2
S112
S12D
SIGN
SVI1
SVI2
SVI3
SVI4
SIPP
SMON
STAB
SCL1
SLD1
STTE
SCSI
TYPE
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
WIDTH
2.0
2.0
2.0
4.0
25.0
1.0 50
60.0
4.0
1.0
1.0
1.0
1.0
5.0
1.0
2.0
2.0
25.0
2.0
1.0
COMMENT
Also see NAICS acroynms: NIC1.NICS,
NCD1.SICN
For ad hoc use.
EPA DATA
STANDARD
MDR?
N
N
OBSOLETE
N
N
OBSOLETE
OBSOLETE
N
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
OBSOLETE
N
N
N
Y
N
PAGE 6 OF 7
PLANT GENERAL
-------
DATA ELEMENT NAME
STATE COMPLIANCE STATUS DESC
STATE COUNTY EMISSIONS SOURCE
STATE EMISSIONS DATA ELEMENT 1
STATE EMISSIONS DATA ELEMENT 9
STATE NAME
STATE PRIVATE INDICATOR
STATE REGISTRATION NUMBER
STATE-COUNTY-SOURCE ID
STATUS AREA
SUB CATEGORY
SUB CATEGORY DESC
TELEPHONE AREA CODE COMPLIANCE
TELEPHONE AREA CODE EMISSIONS
TELEPHONE NUMBER COMPLIANCE
TELEPHONE NUMBER EMISSIONS
TERTIARY INDUSTRIAL CLASS CODE
TERTIARY SIC DESCRIPTION
USER PLANT ID
UTM ZONE
YEAR OF EMISSIONS INVENTORY
ZIP CODE
DATA ELEMENT DEFINITION
A system generated description of the State bubble-up value
of the most serious compliance status of air program
pollutants at a plant. The most serious case (worst to best)
is bubbled-up from the State value. Compliance values fall
within 4 categories: In Compliance, Out of Compliance, On
Schedule, and Unknown Compliance. Sources with
unaddressed High Priority Violations should be listed as Out
of Compliance. Title V Annual Compliance Certifications
with deviations may or may not be listed as Out of
Compliance. See Air Program pollutants for individual
values. See the Data Dictionary for all valid values.
OBSOLETE
OBSOLETE
OBSOLETE
System generated field which identifies the state which a
plant is located within.
An optional field available only to authorized state users
indicating whether informaiton contained on a record is not
federally reportable and designated state private. Valid
values are Y=Yes, N=No. Y on SP1 1 indicates that the
entire plant is State Private.
Optional value, a state assigned identifier used to identify a
plant. Usually a value from a state system.
Optional use field in retrievals. A 10-digit character field
identifying a facility through the concatenation of the FIPS
State, FIPS County, and PCDS source ID number.
OBSOLETE
OBSOLETE
OBSOLETE
Optional use field. Telephone area code of a compliance
program contact.
OBSOLETE
Optional use field. Telephone number of a compliance
program contact.
OBSOLETE
An optional code identifying the tertiary Standard Industrial
Code (SIC) classifying the third most prominent product
produced or service performed at the plant.
Sysem generated value of the tertiary SIC description.
OBSOLETE
OBSOLETE
OBSOLETE
Mandatory field, the zip code for the plant address.
ACROYNM
SDS1
SCSE
SD01
SD09
STNM
SP11
STRS
SCSC
STAT
MACS
MCSD
TLAC
TLAE
TLNC
TLNE
SIC3
SCD3
UDPL
UTZ1
YINV
ZIPC
TYPE
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
N
A
A
WIDTH
25.0
9.0
3.0
30.0
20.0
1.0
15.0
10.0
5.0
4.0
60.0
3.0
3.0
7.0
7.0
4.0
25.0
12.0
2.0
2.0
9.0
COMMENT
Spells out a state name.
Update access limited to authorized state
users.
Although optional, it is recommended that
this value be populated in AFS if there is
a corresponding state/local value.
Commonly known as the AFS ID number,
not to be confused with the AFS Permit
ID number, PAFS. Key number for
Envirofacts sources.
Also see NAICS acroynms: NIC1.NICS,
NCD1.SICN
Reported in conjunction with the Plant
Street Address and City.
EPA DATA
STANDARD
MDR?
N
OBSOLETE
OBSOLETE
OBSOLETE
N
N
N
N
OBSOLETE
OBSOLETE
OBSOLETE
N
OBSOLETE
N
OBSOLETE
N
N
OBSOLETE
OBSOLETE
OBSOLETE
Y
PAGE 7 OF 7
PLANT GENERAL
-------
This Page Intentionally Left Blank
-------
Appendix 3a
AFS Regional Action Types
-------
This Page Intentionally Left Blank
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 01
FULL COMPLIANCE EVALUATIONS (FCE)
National
AA-N
AB-N
FE-N
FZ-N
FF-N
FS-N
Region State REGIONAL ACTION DESCRIPTION:
AA-R FEDERAL AIR TOXICS ONSITE FCE
AK-R FEDERAL AIR TOXICS OFFSITE FCE
FE-R EPA CONDUCTED FCE/ON-SITE
FZ-R EPA CONDUCTED FCE/OFF-SITE
FF-R STATE CONDUCTED FCE/OFF-SITE
FS-R STATE CONDUCTED FCE/ON-SITE
Additional Reguirements
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
Region State REGIONAL ACTION DESCRIPTION:
AE-R FEDERAL AIR TOXICS INVESTIGATION INITIATED
AQ-R FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EC-R EPA INVESTIGATION CONDUCTED
EI-R EPA INVESTIGATION STARTED
SC-R STATE INVESTIGATION CONDUCTED
SI-R STATE INVESTIGATION STARTED
Additional Reguirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reportina State PCE's are currently an ODtion.)
National
AC-N
AD-N
ES-N
ES-N
ES-N
ES-N
ES-N
ES-N
EX-N
EX-N
EX-N
EX-N
EX-N
PS-N
PS-N
PS-N
PS-N
PS-N
PS-N
PS-N
PS-N
PS-N
PS-N
PS-N
PX-N
PX-N
PX-N
PX-N
Region State REGIONAL ACTION DESCRIPTION:
AM-R FEDERAL AIR TOXICS ONSITE PCE
AR-R FEDERAL AIR TOXICS OFFSITE PCE
EP-R EPA ON-SITE INSP. PIECE OF AN FCE
ES-R EPA CONDUCTED PCE/ON-SITE
J5-R VISIBLE EMISSIONS EVALUATION (RM9) BY EPA
M6-R EPA CMS QA OBSERVATION (60.13)
M8-R EPA CMS AUDIT CONDUCTED
R7-R EPA COMPLAINT INSPECTION
EX-R EPA CONDUCTED PEC/OFF-SITE
X9-R CAA SECTION 114 LETTER RESPONSE REVIEWED BY EPA
XM-R MACT (PART 63) REPORT REVIEWED BY EPA
XN-R NSPS (PART 60) REPORT REVIEWED BY EPA
XO-R OTHER (NON-NSPS, NON-MACT) REPORT REVIEWED BY EPA
14-R STATE PARTIAL INSPECTION
15-R STATE VISIT FOR PERMITTING
17-R STATE COMPLAINT INSPECTION
36-R SAMPLE TAKEN
A9-R SOURCE REGISTRATION VERIFIED BY INSPECTION
J7-R VISIBLE EMISSION EVALUATION (RM9) BY STATE
M2-R STATE CMS AUDIT CONDUCTED
M5-R STATE CMS QA OBSEERVATION (60.13)
PS-R STATE PCE/ON-SITE
SP-R STATE ON-SITE INSP. PIECE OF AN FCE
U9-R STATE MULTIMEDIA INSPECTION - LEVEL 2 OR GREATER
39-R REPORT TO STATE
A8-R SOURCE REGISTRATION RECEIVED
E4-R EMISSION TEST RESULTS REVIEWED BY STATE
PX-R STATE CONDUCTED PCE/OFF-SITE
Additional Reguirements
STACK TESTS
National
SS-N
TE-N
TO-N
TT-N
3A-N
ST-N
TR-N
TS-N
Region State REGIONAL ACTION DESCRIPTION:
SS-R EPA NON-MDR STACK TEST
TE-R EPA REQ (O/O COND) STACK TEST/NOT OBSVD BUT REVWD
M7-R PERFORMANCE TEST EPA REQUIRED
TT-R EPA RECEIPT OF STACK TEST REPORT
E2-R EMISSION TEST STATE REQUIRED
SU-R AGENCY NON-MDR STACK TEST
TR-R STATE REQ (O/O COND) STACK TEST/NOT OBSVD BUT REVD
TS-R STATE RECEIPT OF STACK TEST REPORT
Additional Reguirements
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF).
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 1
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 01
NOTICE OF VIOLATIONS
National Region State REGIONAL ACTION DESCRIPTION:
6A-N BA-R EPA NOTICE OF VIOLATION
7C-N 28-R STATMENT OF DEFICIENT PRACTICES
7C-N AB-R STTE NOTICE OF VIOLATION
7C-N AN-R STATE NOTICE OF NON-COMPLIANCE
7C-N L1-R NOV ISSUED BY STATE
FEDERAL ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
6B-N
7F-N
8A-N
8A-N
AG-N
AH-N
C2-N
EPA CONSENT DECREE
EPA ADMINISTRATIVE PENALTY ORDER 113(D)
EPA 113A SIP VIOLATION ORDER ISSUED
EPA 113A NON-SIP VIOLATION ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
EPA CONSENT AGREEMENT FINAL ORDER
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
Additional Reguirements
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N X2-R STATE COURT DECREE ISSUED
8C-N 56-R STATE CONSENT AGREEMENT ISSUED
8C-N X1-R STATE ORDER ISSUED
8C-N Z7-R STATE ADMIN FINE BY CONSENT AGREEMENT SIGNED
8C-N Z8-R STTE NOTICE PROP FINE&HEARING, PAID W/O SIGNED AFC
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N
4B-N
AI-N
AJ-N
1E-N
3D-N
9C-N
G1-R
Z4-R
L2-R
CIVIL ACTION REFERRED TO EPA HEADQUARTERS
EPA CIVIL ACTION (REFERRAL)
FEDERAL AIR TOXICS REFERRAL TO DOJ
NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
REFER TO STATE ATTORNEY GENERAL
STATE CIVIL PENALTY
CIVIL ACTION BY STATE
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Reguirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
Violation
2B-N 2B-R 2B-R DAY ZERO - SHARED ENFORCEMENT LEAD PLC1, Lead Agency
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED PLC1, Lead Agency
2Z-N J1-R FEDERAL DAY ZERO PLC1, Lead Agency
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N V3-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N W1-R STATE DAY ZERO PLC1, Lead Agency
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 2
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 01
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National Region State REGIONAL ACTION DESCRIPTION:
OT-N OT-R OT-R OTHER ADDRESSING ACTION
2M-N V7-R PROP SIP OR FIP REVISION WILL LEAD TO COMPLIANCE
6B-N RA-R EPA CONSENT DECREE
7F-N Y9-R EPA ADMINISTRATIVE PENALTY ORDER 11 3(D)
8A-N Y1-R EPA 113A SIP VIOLATION ORDER ISSUED
8A-N Y2-R EPA 113A NON-SIP VIOLATION ORDER ISSUED
AG-N AO-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
2D-N X2-R STATE COURT DECREE ISSUED
8C-N 56-R STATE CONSENT AGREEMENT ISSUED
8C-N X1-R STATE ORDER ISSUED
8C-N Z7-R STATE ADMIN FINE BY CONSENT AGREEMENT SIGNED
8C-N Z8-R STTE NOTICE PROP FINE&HEARING, PAID W/O SIGNED AFC
9C-N L2-R CIVIL ACTION BY STATE
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National Region State REGIONAL ACTION DESCRIPTION:
C7-N DC-R DC-R CLOSEOUT MEMO ISSUED
VR-N VA-R VA-R VIOLATION RESOLVEDD
7G-N V6-R SOUR RET TO COMPL BY US EPA W/ NO FURTHER ACT REQ
AH-N AP-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
2K-N V5-R SOUR RET TO COMPL BY STATE W/ NO FURTHER ACT REQ
C7-N DC-R CLOSEOUT MEMO ISSUED
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS
National Region State REGIONAL ACTION DESCRIPTION:
CC-N CC-R CC-R TITLE V ANNUAL COMPL CERT DUE/RECEIVED BY EPA
ER-N ER-R COMPLIANCE CERTIFICATION EPA REVIEW
CB-N CB-R TITLE V COMPLIANCE CERT. DUE/RCVD BY STATE/LOCAL
SR-N SR-R COMPLIANCE CERTIFICATION STATE REVIEW
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
Additional Reguirements
PAM1
requirements.)
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation, MC-in Compliance, MU-Unknown.
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Reguirements
NA-N NM-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 3
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 01
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data Additional
Permitting Authority Name FIPS Tables
PAFS
PAPN
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
X (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
X (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 0 Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 1 Plant Lvl
SPT1 APC1=8
SPT1 APC1=M
SPT1 APC1=0
SPT1 APC1=1
X
X
X
X
X
APPENDIX 3A-PAGE 4
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 02
FULL COMPLIANCE EVALUATIONS (FCE)
National
AA-N
AB-N
FE-N
FZ-N
FF-N
FS-N
Region State REGIONAL ACTION DESCRIPTION:
AA-R FEDERAL AIR TOXICS ONSITE FCE
AB-R FEDERAL AIR TOXICS OFFSITE FCE
FE-R EPA CONDUCTED FCE/ON-SITE
F1-R EPA CONDUCTED FCE/OFF-SITE
FF-R STATE CONDUCTED FCE/OFF-SITE
FS-R STATE CONDUCTED FCE/ON-SITE
Additional Reguirements
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
Region State REGIONAL ACTION DESCRIPTION:
AL-R FEDERAL AIR TOXICS INVESTIGATION INITIATED
AF-R FEDERAL AIR TOXICS INVESTIGATION COMPLETED
CE-R EPA INVESTIGATION CONDUCTED
IE-R EPA INVESTIGATION STARTED
CS-R STATE INVESTIGATION CONDUCTED
SI-R STATE INVESTIGATION STARTED
Additional Reguirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reportina State PCE's are currently an ODtion.)
National
AC-N
AD-N
EE-N
EM-N
EO-N
EP-N
ES-N
ES-N
ES-N
ES-N
ES-N
ES-N
EX-N
EX-N
PC-N
PO-N
PP-N
PR-N
PS-N
PS-N
PS-N
PS-N
PS-N
PX-N
PX-N
Region State REGIONAL ACTION DESCRIPTION:
AK-R FEDERAL AIR TOXICS ONSITE PCE
AD-R FEDERAL AIR TOXICS OFFSITE PCE
EE-R COMPLAINT ON-SITE PCE (EPA)
EM-R PROCESS OFF-SITE PCE (EPA)
EO-R ON-SITE PCE OBSERVATION (EPA)
EP-R PERMIT ON-SITE PCE (EPA)
50-R EPA SOURCE INSPECTION - LEVEL 2 OR GREATER
53-R EPA SOURCE TEST
58-R EPA PRIMACY INSPECTION - LEVEL 2 OR GREATER
ES-R EPA PCE/ON-SITE
L4-R EPA CASE DEVELOPMENT INSPECTION - LEVEL 2 OR GRTR
MM-R MULTIMEDIA INSPECTION (EPA) - LEVEL 2 OR GREATER
E2-R EER REVIEWED BY EPA
EX-R EPA PCE/OFF-SITE
PC-R COMPLAINT ON-SITE PCE (STATE)
PO-R ON-SITE PCE OBSERVATION (STATE)
PP-R PERMIT ON-SITE PCE (STATE)
PR-R PROCESS OFF-SITE PCE (STATE)
IC-R COMPLAINT INSPECTION BY STATE
PS-R STATE PCE/ON-SITE
S8-R INSPECTION BY STATE - LEVEL 2 OR GREATER
S9-R STATE SOURCE TEST
SS-R SAMPLE COLLECTED BY STATE
PX-R STATE CONDUCTED PCE/OFFSITE
TP-R PERIODIC REPORT
Additional Reguirements
STACK TESTS
National
2A-N
SS-N
TE-N
TO-N
TT-N
3A-N
6C-N
ST-N
TR-N
TS-N
Region State REGIONAL ACTION DESCRIPTION:
2A-R EPA CONDUCTED STACK TEST
SN-R EPA NON-MDR STACK TEST
TE-R EPA REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
TO-R EPA REQ (O/O COND) STACK TEST/OBSERVED & REVIEWED
TT-R EPA RECEIPT OF STACK TEST REPORT
3A-R STATE REQ (O/O COND) STACK TEST/OBSV & REVIEWED
6S-R STATE CONDUCTED STACK TEST
ST-R AGENCY NON-MDR STACK TEST
TR-R STATE REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
SV-R STATE RECEIPT OF STACK TEST REPORT
Additional Reguirements
Results Code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 5
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING:REGION
02
NOTICE OF VIOLATIONS
National Region State REGIONAL ACTION DESCRIPTION:
6A-N 55-R EPA NOTICE OF VIOLATION
6A-N 6A-R EPA NOV ISSUED
7A-N 7A-R EPA NOTICE OF NONCOMPLIANCE (SECTION120) ISSUED
7C-N L1-R NOV ISSUED BY STATE
FEDERAL ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
6B-N 6B-R EPA CONSENT DECREE
6B-N X3-R FEDERAL COURT DECREE ISSUED
7E-N 7E-R EPA SECTION 167 ORDER ISSUED
7E-N P1-R 167 STOP CONSTRUCTION ORDER
7F-N 7F-R 113DAPO COMPLAINT FILED
8A-N 56-R EPA ABATEMENT ORDER ISSUED
8A-N 8A-R 113A ORDER ISSUED
8A-N Y1-R EPA 113A SIP VIOLATION ORDER ISSUED
8A-N Y2-R EPA 113A NON-SIP VIOLATION ORDER ISSUED
AG-N AM-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-N AH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
C2-N C2-R 113(D)APO RECALCULATED
C3-N C3-R 113(D) ADMINISTRATIVE PENALTY COLLECTED
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
Additional Reguirements
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N 2D-R STATE CONSENT DECREE PAM1 (TolaI Assessed)
2D-N
8C-N
8C-N
8C-N
CIVIL AND
X2-R STATE COURT DECREE ISSUED
4L-R NOTICE OF HEARING SENT TO SOURCE OWNER
8C-R STATE ADMINISTRATIVE ORDER
X1-R STATE ORDER ISSUED
CRIMINAL REFERRALS AND PENALTY AMOUNTS
Region State REGIONAL ACTION DESCRIPTION:
EPA CIVIL ACTION (REFERRAL)
EPA CIVIL ACTION (REFERRAL)
REFERRED TO DEPARTMENT OF JUSTICE BY EPA
EPA CRIMINAL ACTION
EPA CRIMINAL ACTION
FEDERAL CIVIL PENALTY
FEDERAL AIR TOXICS REFERRAL TO DOJ
NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
CRIMINAL REFERRAL
STATE CRIMINAL ACTION
CIVIL REFERRAL TO STATE AG
REFER TO STATE ATTORNEY GENERAL
STATE CIVIL PENALTY
STATE CIVIL ACTION
REFER TO NEW YORK STATE ATTORNEY GENERAL
CIVIL ACTION BY STATE
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 6
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 02
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked. Comment on Day Zero documents type of
Violation
2B-N 2B-R 2B-R DAY ZERO - SHARED ENFORCEMENT LEAD
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED
2Z-N FZ-R FEDERAL DAY ZERO
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N DY-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N SZ-R STATE DAY ZERO
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National Region State REGIONAL ACTION DESCRIPTION:
2M-N 2M-R 2M-R PROP SIP/FIP REVISION WILL LEAD TO COMPLIANCE
OT-N OT-R OT-R OTHER ADDRESSING ACTION
6B-N 6B-R EPA CONSENT DECREE
6B-N X3-R FEDERAL COURT DECREE ISSUED
7A-N 7A-R EPA NOTICE OF NONCOMPLIANCE (SECTION120) ISSUED
7A-N Z2-R NOTICE OF NON-COMPLIANCE
7E-N 7E-R EPA SECTION 167 ORDER ISSUED
7E-N P1-R 167 STOP CONSTRUCTION ORDER
7F-N 7F-R 113DAPO COMPLAINT FILED
8A-N 56-R EPA ABATEMENT ORDER ISSUED
8A-N 8A-R 113A ORDER ISSUED
8A-N Y1-R EPA 113A SIP VIOLATION ORDER ISSUED
8A-N Y2-R EPA 113A NON-SIP VIOLATION ORDER ISSUED
AG-N AM-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-N AH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
2D-N 2D-R STATE CONSENT DECREE
2D-N X2-R STATE COURT DECREE ISSUED
8C-N 4L-R NOTICE OF HEARING SENT TO SOURCE OWNER
8C-N 8C-R STATE ADMINISTRATIVE ORDER
8C-N X1-R STATE ORDER ISSUED
9C-N 9C-R STATE CIVIL ACTION
9C-N AG-R REFER TO NEW YORK STATE ATTORNEY GENERAL
9C-N L2-R CIVIL ACTION BY STATE
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National Region State REGIONAL ACTION DESCRIPTION:
C7-N C7-R C7-R CLOSEOUT MEMO ISSUED
VR-N VR-R VR-R VIOLATION RESOLVED
WD-N WD-R WD-R WITHDRAWN
7G-N 7G-R SOUR RET TO COMPL BY US EPA W/NO FURTHER ACT REQ
C3-N C3-R 113(D) ADMINISTRATIVE PENALTY COLLECTED
2K-N 2K-R SOUR RET TO COMPL BY STTE W/NO FURTHER ACT REQ
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUS(Note: contains new CMS
National Region State REGIONAL ACTION DESCRIPTION:
CC-N CC-R CC-R TITLE V COMPLIANCE CERT. DUE/RECEIVED BY EPA
ER-N ER-R TITLE V COMPLIANCE CERTIFICATION REVIEW BY EPA
CB-N CB-R TV ANNUAL COMPL. CERT DUE/RECV BY PERM. AUTHORITY
SR-N SR-R COMPLIANCE CERTIFICATION REVIEW
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
PLC1 , Lead Agency
PLC1 , Lead Agency
PLC1 , Lead Agency
PLC1 , Lead Agency
Additional Reguirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
Additional Reguirements
reguirements.)
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation, MC-in Compliance, MU-Unknown.
RDE8=Deviation, Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Reguirements
NA-N NA-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NM-N NM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 7
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 02
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data
Permitting Authority Name
PAFS
PAPN
Additional
FIPS Tables
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
X (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
X (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 0 Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 1 Plant Lvl
SPT1 APC1=8
SPT1 APC1=M
SPT1 APC1=0
SPT1 APC1=1
X
X
X
X
X
APPENDIX 3A-PAGE 8
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 03
FULL COMPLIANCE EVALUATIONS (FCE)
National Region State REGIONAL ACTION DESCRIPTION:
AA-N AA-R FEDERAL AIR TOXICS ONSITE FCE
AB-N AB-R FEDERAL AIR TOXICS OFFSITE FCE
FE-N 10-R EPA CONDUCTED FCE/ON-SITE
FE-N FE-R EPA CONDUCTED FCE/ON-SITE
FZ-N 11-R EPA CONDUCTED FCE/OFF-SITE
FZ-N FZ-R EPA CONDUCTED FCE/OFF-SITE
FF-N FF-R STATE CONDUCTED FCE/ OFF-SITE
FS-N 08-R STATE CONDUCTED FCE/ON-SITE
FS-N 81 -R STATE INSPECTION STAGE 1 VAPOR RECOVERY
FS-N 82-R STATE INSPECTION STAGE 2 VAPOR RECOVERY
FS-N FS-R STATE CONDUCTED FCE/ON-SITE
FS-N PO-R P/O INSPECTION
FS-N SI-R STATE MULTIMEDIA INSPECTION
INVESTIGATIONS
National Region State REGIONAL ACTION DESCRIPTION:
AE-N * AE-R FEDERAL AIR TOXICS INVESTIGATION INITIATED
AF-N AF-R FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EC-N 3R-R EPA INVESTIGATION COMPLETED
EI-N * RI-R REGION III INVESTIGATION
SC-N IC-R STATE INVESTIGATION COMPLETED
SI-N * IS-R STATE INVESTIGATION STARTED
Additional Reguirements
Additional Reguirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reportina State PCE's are currently an ODtion.)
National Region State REGIONAL ACTION DESCRIPTION:
AC-N A1-R FEDERAL AIR TOXICS ONSITE PCE
AD-N A2-R FEDERAL AIR TOXICS OFFSITE PCE
EE-N EE-R COMPLAINT ON-SITE PCE (EPA)
EM-N EM-R PROCESS OFF-SITE PCE (EPA)
EO-N EO-R ON-SITE PCE OBSERVATION (EPA)
EP-N EN-R PERMIT ON-SITE PCE (EPA)
ES-N ES-R EPA CONDUCTED PCE/ ON-SITE
EX-N EP-R EPA CONDUCTED PCE/ OFF-SITE
PC-N PD-R COMPLAINT ON-SITE PCE (STATE)
PO-N PT-R ON-SITE PCE OBSERVATION (STATE)
PP-N PP-R PERMIT ON-SITE PCE (STATE)
PR-N PQ-R PROCESS OFF-SITE PCE (STATE)
PS-N PS-R STATE CONDUCTED PCE/ ON-SITE
PX-N 74-R EXCESS EMISSION REPORT REVIEWED
PX-N PX-R STATE CONDUCTED PCE/ OFF-SITE
STACK TESTS
National Region State REGIONAL ACTION DESCRIPTION:
2A-N 12-R EPA STACK TEST
SS-N SS-R EPA NON-MDR STACK TEST
TE-N 14-R EPA STACK TEST REVIEW -LEVEL 2 OR GREATER
TO-N 13-R EPA OBSERVED STACK TEST
TT-N TT-R EPA RECEIPT OF STACK TEST REPORT
3A-N 18-R STATE OBSERVED STACK TEST
3A-N 73-R NEW SOURCE PERFORMANCE TEST
6C-N 16-R STATE STACK TEST
ST-N ST-R AGENCY NON-MDR STACK TEST
TR-N 15-R SOURCE OPERATOR STACK TEST
TS-N TS-R STATE RECEIPT OF STACK TEST REPORT
NOTICE OF VIOLATIONS
National Region State REGIONAL ACTION DESCRIPTION:
6A-N 23-R EPA NOV ISSUED
7A-N 80-R SECTION 120 NOTICE OF NONCOMPLIANCE
7C-N 49-R STATE NOTICE OF VIOLATION ISSUED
Additional Reguirements
Additional Reguirements
Results Code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF).
Additional Reguirements
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 9
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 03
FEDERAL ORDERS AND PENALTY AMOUNTS
National
6B-N
6B-N
6B-N
7E-N
7F-N
7F-N
8A-N
8A-N
8A-N
AG-N
AH-N
C2-N
C3-N
Region
31-R
32-R
MD-R
SC-R
7F-R
MA-R
33-R
34-R
35-R
AG-R
AH-R
AO-R
AC-R
State REGIONAL ACTION DESCRIPTION:
EPA COURT CONSENT DECREE ENTERED
FEDERAL COURT ORDER
MULTIMEDIA CONSENT DECREE
SECTION 167 PSD STOP CONSTRUCTION ORDER
113D APO COMPLAINT FILED.
MULTIMEDIA ADMINISTRATIVE PENALTY ORDER
EPA 113(A) (1) 30-DAY SIP ORDER
EPA 113(A) (3) NON-SIP ORDER
EPA 113(A) (5) STOP CONSTRUCTION ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
113(D) APO RECALCULATED
ADMINISTRATIVE CIVIL PENALTY COLLECTED
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: Orders include Penalty Notices,Compliance Notices.Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N
2D-N
8C-N
8C-N
45-R STATE COURT ORDER ISSUED
46-R STATE COURT CONSENT DECREE SIGNED
47-R STATE ADMINISTRATIVE UNILATERAL ORDER
48-R STATE ADMINISTRATIVE CONSENT AGREEMENT
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N
4B-N
4B-N
4B-N
5B-N
7B-N
AI-N
AJ-N
1D-N
1E-N
1E-N
3D-N
9C-N
44-R
CR-R
SM-R
92-R
43-R
REFERRAL TO DSSE
REFER TO JUSTICE
EPA CIVIL ACTION FILED (REFERRAL)
MULTIMEDIA REFERRAL
EPA CRIMINAL ACTION FILED
EPA CIVIL PENALTY ASSESSED
FEDERAL AIR TOXICS REFERRAL TO DOJ
NONAPPLICABILITY OF AIR TOXIC REQUIREMENT
STATE CRIMINAL ACTION FILED
STATE CIVIL REFERRAL
STATE MULTIMEDIA CIVIL REFERRAL
STATE CIVIL PENALTY ASSESSED
STATE CIVIL ACTION FILED
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
Violation
2B-N
2B-R 2B-R DAY ZERO-SHARED ENFORCEMENT LEAD
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED
2Z-N DZ-R FEDERAL DAY ZERO
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N DY-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N 2E-R STATE DAY ZERO
PLC1, Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 10
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING:
REGION
03
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National Region State REGIONAL ACTION DESCRIPTION:
2M-N 2M-R 2M-R PROP SIP OR FIP REVISION WILL LEAD TO COMPLIANCE
OT-N OT-R OT-R OTHER ADDRESSING ACTION
6B-N 31-R EPA COURT CONSENT DECREE ENTERED
6B-N 32-R FEDERAL COURT ORDER
6B-N MD-R MULTIMEDIA CONSENT DECREE
7A-N 80-R SECTION 120 NOTICE OF NONCOMPLIANCE
7E-N SC-R SECTION 167 PSD STOP CONSTRUCTION ORDER
7F-N 7F-R 113DAPO COMPLAINT FILED.
7F-N MA-R MULTIMEDIA ADMINISTRATIVE PENALTY ORDER
8A-N 33-R EPA 113(A)(1) 30-DAY SIP ORDER
8A-N 34-R EPA 113(A) (3) NON-SIP ORDER
8A-N 35-R EPA 1 13 (A) (5) STOP CONSTRUCTION ORDER
AG-N AG-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-N AH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
2D-N 45-R STATE COURT ORDER ISSUED
2D-N 46-R STATE COURT CONSENT DECREE SIGNED
2L-N 07-R SIP REVISION PENDING
8C-N 47-R STATE ADMINISTRATIVE UNILATERAL ORDER
8C-N 48-R STATE ADMINISTRATIVE CONSENT AGREEMENT
9C-N 43-R STATE CIVIL ACTION FILED
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National Region State REGIONAL ACTION DESCRIPTION:
C7-N CO-R CO-R CASE CLOSE-OUT
VR-N VR-R VR-R VIOLATION RESOLVED
WD-N WD-R WD-R WITHDRAWN
7G-N 7G-R SOURCE RET TO COMPL BY EPA W/NO FURTHER ACT REQ
C3-N AC-R ADMINISTRATIVE CIVIL PENALTY COLLECTED
2K-N 2K-R SOURCE RET TO COMPL BY STATE W/NO FURTHER ACT REQ
2K-N 2L-R HPV ADDRESSED/RESOLVED BY STATE UNDEFINED ACTION
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS
National Region State REGIONAL ACTION DESCRIPTION:
CC-N CC-R CC-R COMPLIANCE CERTIFICATIONS DUE/RECEIVED BY EPA
ER-N ER-R REVIEWED FOR DEVIATION
CB-N CB-R TITLE V COMPLIANCE CERT DUE/RECEIVD BY STATE/LOCAL
SR-N SN-R COMPLIANCE CERTIFICATION STATE REVIEW
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
Additional Reguirements
reguirements.)
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation, MC-in Compliance, MU-Unknown.
RDE8=Deviation, Y-Yes and N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Reguirements
NA-N NA-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NM-N NM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 11
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 03
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data
Permitting Authority Name
PAFS
PAPN
Additional
FIPS Tables
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
X (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
X (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 0 Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 1 Plant Lvl
SPT1 APC1=8
SPT1 APC1=M
SPT1 APC1=0
SPT1 APC1=1
X
X
X
X
X
APPENDIX 3A-PAGE 12
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 04
FULL COMPLIANCE EVALUATIONS (FCE)
National
AA-N
AB-N
FE-N
FZ-N
FF-N
FS-N
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE FCE
FEDERAL AIR TOXICS OFFSITE FCE
EPA CONDUCTED FCE/ ON-SITE
EPA CONDUCTED FCE/ OFF-SITE
FF-R STATE CONDUCTED FCE/ OFF-SITE
FS-R STATE CONDUCTED FCE/ ON-SITE
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS INVESTIGATION INITIATED
FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EPA INVESTIGATION CONDUCTED
EPA INVESTIGATION STARTED
SC-R STATE INVESTIGATION CONDUCTED
SI-R STATE INVESTIGATION STARTED
Additional Requirements
Additional Requirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reporting State PCE's are currently an option.)
National
AC-N
AD-N
EE-N
EM-N
EO-N
EP-N
ES-N
EX-N
PC-N
PO-N
PP-N
PR-N
PS-N
PS-N
PS-N
PX-N
PX-N
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE PCE
FEDERAL AIR TOXICS OFFSITE PCE
COMPLAINT ON-SITE PCE (EPA)
PROCESS OFF-SITE PCE (EPA)
ON-SITE PCE OBSERVATION (EPA)
PERMIT ON-SITE PCE (EPA)
EPA CONDUCTED PCE/ ON-SITE
EPA CONDUCTED PCE/ OFF-SITE
PC-R COMPLAINT ON-SITE PCE (STATE)
PO-R ON-SITE PCE OBSERVATION (STATE)
PP-R PERMIT ON-SITE PCE (STATE)
PR-R PROCESS OFF-SITE PCE (STATE)
27-R STATE COMPLIANCE INSPECTION - LEVEL 2 OR GREATER
54-R STATE REINSPECTION - LEVEL 2 OR GREATER
PS-R STATE CONDUCTED PCE/ ON-SITE
PX-R STATE CONDUCTED PCE/ OFF-SITE
SD-R SELF DISCLOSED VIOLATION
Additional Requirements
STACK TESTS
State
REGIONAL ACTION DESCRIPTION:
EPA CONDUCTED STACK TEST
EPA REQ (O/O COND) STACK TEST/NOT OBSVD BUT REVWD
EPA REQ (O/O COND) STACK TEST/ OBSERVED & REVIEWED
STATE REQ (O/O COND) STACK TEST/OBSVD & REVIEWED
NSPS PERFORMANCE TEST
SOURCE TEST OBSERVED
NESHAPS SOURCE TEST
STATE CONDUCTED STACK TEST
STATE EVALUATED SOURCE TEST REPORT
STATE REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
STATE RECEIPT OF STACK TEST REPORT
Additional Requirements
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
NOTICE OF VIOLATIONS
National Region State
6A-N
6A-N
6A-N
7A-N
7A-N 74-R
7C-N 56-R
REGIONAL ACTION DESCRIPTION:
NOTICE OF VIOLATION
EPA PSD NOTICE OF VIOLATION
NOV ISSUED BY EPA
NOTICE OF NON-COMPLIANCE
STATE WARNING LETTER SENT
STATE NOTICE OF VIOLATION
Additional Requirements
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 13
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 04
FEDERAL ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
6B-N CB-R FEDERAL CONSENT AGREEMENT SIGNED
6B-N X3-R FEDERAL COURT DECREE ISSUED
7E-N K8-R EPA 167 ORDER ISSUED
7F-N AB-R 113(D) ADMINISTRATIVE COMPLIANT FILED
7F-N AU-R 1 1 3(D) APO COM PLAINTFILED
8A-N B1-R EPA 113(A) ADMINISTRATIVE ORDER ISSUED
8A-N K1-R EPA PSD ORDER
8A-N P9-R EPA NSR ORDER
8A-N V7-R NESHAPS ORDER BY EPA
8A-N Y1-R EPA 113A SIP VIOLATION ORDER ISSUED
8A-N Y2-R EPA 113A NON-SIP VIOLATION ORDER ISSUED
8A-N Y3-R EPA 113A PROHIBIT CONSTRUCTION ORDER ISSUED
AG-N XG-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-N XH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
C3-N AH-R 113(D) ADMINISTRATIVE PENALTY COLLECTED
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
Note: Administrative Orders include Penalty Notices, Compliance Notices.Agreed Orders, Compliance Administrative Orders,
2D-N 31 -R CONSENT ORDER ISSUED
2D-N X2-R STATE COURT DECREE ISSUED
8C-N 40-R STATE CONSENT ORDER
8C-N X1-R STATE ORDER ISSUED
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N * 5B-R EPA NSPS CIVIL ACTION (REFERRAL)
4B-N * B6-R REFERRAL TO DOJ
4B-N * C1-R EPA CIVIL ACTION (REFERRAL)
4B-N * K2-R EPA PSD CIVIL ACTION (REFERRAL)
4B-N * L6-R EPA NSR/PSD CIVIL ACTION (REFERRAL)
4B-N * V8-R EPA NESHAPS CIVIL ACTION (REFERRAL)
5B-N * CA-R EPA CRIMINAL ACTION
7B-N * Z6-R EPA CIVIL PENALTY ASSESSED
AI-N * XI-R FEDERAL AIR TOXICS REFERRAL TO DOJ
AJ-N XJ-R NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
1D-N * 63-R STATE CRIMINAL SUIT FILED BY ATTORNEY GENERAL
1D-N * L3-R STATE CRIMINAL ACTION
1E-N * 60-R STATE REFERRAL TO ATTORNEY GENERAL
3D-N * Z4-R STATE CIVIL PENALTY ASSESSED
9C-N 64-R STATE CIVIL SUIT FILED BY ATTORNEY GENERAL
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
Additional Reguirements
Consent Orders or Final Orders
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
National Region State REGIONAL ACTION DESCRIPTION: Additional Reguirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked. Comment on Day Zero documents type of
Violation
2B-N 06-R 06-R DAY ZERO - SHARED ENFORCEMENT LEAD PLC1 , Lead Agency
2U-N 07-R 07-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED PLC1 , Lead Agency
2Z-N 01-R FEDERAL DAY ZERO PLC1 , Lead Agency
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N AO-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N 04-R STATE DAY ZERO PLC1 , Lead Agency
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 14
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING:
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
REGION
04
National Region State REGIONAL ACTION DESCRIPTION:
2M-N AX-R AX-R PROPOSED SIP OR FIP REV WILL LEAD TO COMPLIANCE
OT-N OT-R OT-R OTHER ADDRESSING ACTION
6B-N CB-R FEDERAL CONSENT AGREEMENT SIGNED
6B-N X3-R FEDERAL COURT DECREE ISSUED
7A-N D5-R NOTICE (OF NON COMPLIANCE)
7A-N Z2-R NOTICE OF NON-COMPLIANCE
7E-N K8-R EPA 167 ORDER ISSUED
7F-N AB-R 113(D) ADMINISTRATIVE COMPLIANT FILED
7F-N AU-R 1 1 3(D) APO COM PLAINTFILED
8A-N 4B-R NSPS ORDER BY EPA
8A-N B1-R EPA 113(A) ADMINISTRATIVE ORDER ISSUED
8A-N K1-R EPA PSD ORDER
8A-N P9-R EPA NSR ORDER
8A-N V7-R NESHAPS ORDER BY EPA
8A-N Y1-R EPA 113A SIP VIOLATION ORDER ISSUED
8A-N Y2-R EPA 113A NON-SIP VIOLATION ORDER ISSUED
8A-N Y3-R EPA 113A PROHIBIT CONSTRUCTION ORDER ISSUED
AG-N XG-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-N XH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
2D-N 31 -R CONSENT ORDER ISSUED
2D-N X2-R STATE COURT DECREE ISSUED
2L-N AV-R PROPOSED SIP REVISION WILL LEAD TO COMPLIANCE
8C-N 40-R STATE CONSENT ORDER
8C-N X1-R STATE ORDER ISSUED
9C-N 64-R STATE CIVIL SUIT FILED BY ATTORNEY GENERAL
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National Region State REGIONAL ACTION DESCRIPTION:
C7-N AQ-R AQ-R CLOSEOUT MEMO ISSUED
VR-N AS-R AS-R VIOLATION RESOLVED
VR-N AZ-R AZ-R HPV RESOLVED - SOURCE RETURNED TO COMPLIANCE
WD-N AK-R AK-R WITHDRAWN
7G-N AT-R SOURCE RET.TO COMPL.BY EPA WITH NO FURT ACTION REQ
C3-N AH-R 113(D) ADMINISTRATIVE PENALTY COLLECTED
2K-N AW-R SOURCE RET.TO COMP.BY STATE WITH NO FURTHER ACT RE
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS
National Region State REGIONAL ACTION DESCRIPTION:
CC-N CC-R CC-R TITLE V COMPLIANCE CERTIFICATION DUE RECVD BY EPA
ER-N ER-R TITLE V COMPLIANCE CERTIFICATION REVIEW BY EPA
CB-N CS-R TITLE V ANNUAL COMPL CERT DUE/RECVD BY STATE/LOCAL
SR-N SR-R TITLE V COMPLIANCE CERTIFICATION REVIEW BY STATE
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
Additional Reguirements
reguirements.)
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation, MC-in Compliance, MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Reguirements
NA-N NA-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NM-N NM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 15
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 04
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data Additional
Permitting Authority Name FIPS Tables
PAFS
PAPN
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
X (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
X (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 0 Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 1 Plant Lvl
SPT1 APC1=8
SPT1 APC1=M
SPT1 APC1=0
SPT1 APC1=1
X
X
X
X
X
APPENDIX 3A-PAGE 16
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 05
FULL COMPLIANCE EVALUATIONS (FCE)
REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE FCE
FEDERAL AIR TOXICS OFFSITE FCE
EPA CONDUCTED FCE/ON-SITE
EPA CONDUCTED FCE/OFF-SITE
STATE CONDUCTED FCE/OFF-SITE
STATE CONDUCTED FCE/ON-SITE
National
AA-N
AB-N
FE-N
FZ-N
FF-N
FS-N
Region State
AA-R
AB-R
L6-R
L7-R
82-R
81 -R
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS INVESTIGATION INITIATED
FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EPA INVESTIGATION CONDUCTED
EPA INVESTIGATION STARTED
42-R STATE INVESTIGATION CONDUCTED
41-R STATE INVESTIGATION STARTED
PARTIAL COMPLIANCE EVALUATIONS (PCE)
National Region State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE PCE
FEDERAL AIR TOXICS OFFSITE PCE
EPA PCE/ON-SITE
114 REPLY REVIEWED
EPA OFF-SITE FILE REVIEW
EPA PCE/OFF-SITE
REPORTABLE MILESTONE REVIEWED
STATE PCE/ON-SITE
STATE PCE/OFF-SITE
FESOP COMPLIANCE CERT REVIEW BY STATE LOCAL
STATE OFF-SITE FILE REVIEW
AC-N
AD-N
ES-N
EX-N
EX-N
EX-N
EX-N
PS-N
PX-N
PX-N
PX-N
AC-R
AD-R
L8-R
55-R
L2-R
L5-R
RM-R
83-R
80-R
FR-R
RF-R
Additional Requirements
Additional Requirements
Additional Requirements
STACK TESTS
National Region
2A-N
SS-N
TE-N
TO-N
3A-N
3A-N
6C-N
ST-N
TR-N
State REGIONAL ACTION DESCRIPTION:
EPA CONDUCTED STACK TEST
EPA NON-MDR STACK TEST
EPA REQ(O/O COND) STACK TEST/NOT OBSVD BUT REVWED
EPA REQ(O/O COND) STACK TEST/OBSERVED & REVIEWED
15-R PERFORMANCE TEST
37-R SOURCE TEST OBSERVED
36-R SOURCE TEST CONDUCTED
ST-R AGENCY NON-MDR STACK TEST
35-R STATE REQ(O/O COND) STACK TEST/NOT OBSVD BUT REVWD
NOTICE OF VIOLATIONS
National Region State
6A-N
6A-N
6A-N
7A-N
7C-N D4-R
7C-N D5-R
7C-N L1-R
REGIONAL ACTION DESCRIPTION:
NOTICE OF VIOLATION ISSUED
FINDING OF VIOLATION ISSUED
EPA SHOW CAUSE LETTER
NOTICE OF NON-COMPLIANCE
STATE WARNING LETTER
LOCAL WARNING LETTER ISSUED
NOV ISSUED BY STATE
Additional Reguirements
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).
Additional Reguirements
*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 17
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING:
FEDERAL ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
REGION 05
6B-N
6B-N
7E-N
7F-N
8A-N
8A-N
8A-N
8A-N
AG-N
AH-N
C2-N
C3-N
C6-N
FEDERAL COURT ORDER ISSUED
DECREE ENTERED
167 STOP CONSTRUCTION ORDER
113(D) ADMINISTRATIVE CIVIL COMPLAINT FILED
EPA 113(A)ORDER ISSUED
EPA 113(A)(5)STOP CONSTRUCTION ORDER ISSUED
FEDERAL FACILITY COMPLIANCE AGREEMENT
EPA UNILATERAL ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
113(D) APO RECALCULATED
113(D) ADMINISTRATIVE PENALTY COLLECTED
CONSENT DECREE/COURT ORDER AMENDMENT
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION: Additional Reguirements
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
X2-R STATE COURT DECREE ISSUED
06-R STATE FORGIVABLE APO ISSUED
07-R STATE NONFORGIVABLE APO ISSUED
08-R STATE COMBINED (F/NF) APO ISSUED
66-R STATE ORDER ISSUED
68-R LOCAL FINDINGS AND ORDERS ISSUED
E9-R STATE UNILATERAL ADMINISTRATIVE ORDER
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N
4B-N
5B-N
7B-N
AI-N
1D-N
1E-N
3D-N
9C-N
REFERRAL TO DSSE(CIVIL)
REF DOJ
EPA CRIMINAL ACTION
FEDERAL CIVIL PENALTY
FEDERAL AIR TOXICS REFERRAL TO DOJ
XA-R STATE REFERRAL (CRIMINAL)
X3-R STATE REFERRAL (CIVIL)
Z4-R STATE CIVIL PENALTY
X1-R FILE BY STATE AG
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Reguirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
Violation
2B-N
2B-R 2B-R DAY ZERO-SHARED ENFORCEMENT LEAD
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED
2Z-N 23-R FEDERAL DAY ZERO
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N DY-R LEAD CHANGED TO FEDERAL ENFORCEMENT
RT-N RT-R RT-R SV REPORT AS ADDRESSED
VL-N VL-R VL-R SV REPORT AS ADDED
2E-N 38-R STATE DAY ZERO
PLC1, Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 18
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 05
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National
2M-N
OT-N
6B-N
6B-N
7A-N
7E-N
7F-N
8A-N
8A-N
8A-N
8A-N
AG-N
AH-N
ED-N
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
9C-N
Region
G4-R
OT-R
D1-R
K8-R
Z2-R
L3-R
U1-R
98-R
E1-R
E7-R
E8-R
AG-R
AH-R
ED-R
State
G4-R
OT-R
X2-R
06-R
07-R
08-R
66-R
68-R
E9-R
X1-R
REGIONAL ACTION DESCRIPTION:
PROPOSED PERMIT/SIP/FIP REV WILL LEAD TO COMPLIANC
OTHER ADDRESSING ACTION
FEDERAL COURT ORDER ISSUED
DECREE ENTERED
NOTICE OF NON-COMPLIANCE
167 STOP CONSTRUCTION ORDER
1 13(D) ADMINISTRATIVE CIVIL COMPLAINT FILED
EPA 113(A)ORDER ISSUED
EPA 113(A)(5)STOP CONSTRUCTION ORDER ISSUED
FEDERAL FACILITY COMPLIANCE AGREEMENT
EPA UNILATERAL ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
EPA DEMAND LETTER
STATE COURT DECREE ISSUED
STATE FORGIVABLE APO ISSUED
STATE NONFORGIVABLE APO ISSUED
STATE COMBINED (F/NF) APO ISSUED
STATE ORDER ISSUED
LOCAL FINDINGS AND ORDERS ISSUED
STATE UNILATERAL ADMINISTRATIVE ORDER
FILE BY STATE AG
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National
C7-N
VR-N
WD-N
7G-N
C3-N
2K-N
State REGIONAL ACTION DESCRIPTION:
K9-R CLOSEOUT MEMO ISSUED
44-R VIOLATION RESOLVED
WD-R WITHDRAWN
SOURCE RET TO COMPL BY USEPA W/ NO FURTHER ACT REQ
113(D) ADMINISTRATIVE PENALTY COLLECTED
A4-R SOURCE RETURNED TO COMPL BY THE STATE W/NO ACT RE
Additional Requirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
Additional Requirements
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS requirements.)
National
CC-N
ER-N
CB-N
SR-N
State REGIONAL ACTION DESCRIPTION:
CC-R TITLE V COMPLIANCE CERT DUE/RECEIVED BY EPA
COMPLIANCE CERTIFICATION EPA REVIEW
CB-R
SR-R
TITLE V COMPLIANCE CERT DUE/RECEIVD BY STATE/LOCAL
COMPLIANCE CERTIFICATION STATE REVIEW
Additional Requirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation,MC-in Compliance,MU-Unknown.
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
AJ-N AJ-R NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
NA-N M1-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NM-N NM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
Additional Requirements
APPENDIX 3A-PAGE 19
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 06
FULL COMPLIANCE EVALUATIONS (FCE)
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE FCE
FEDERAL AIR TOXICS OFFSITE FCE
EPA CFC EXPORTER INSPECTION - LEVEL 2 OR GREATER
EPA CONDUCTED FCE/ ON-SITE
EPA CFC IMPORTER INSPECTION - LEVEL 2 OR GREATER
EPA CASE DEVELOPMENT INSPECTION: LEVEL 2 OR GREATR
PRIMACY INSPECTION - LEVEL 2 OR GREATER
EPA MULTI-MEDIA INSPECTION - LEVEL 2 OR GREATER
EPA CFC PRODUCER INSPECTION - LEVEL 2 OR GREATER
EPA OVERVIEW INSPECTION - LEVEL 2 OR GREATER
EPA CFC USER INSPECTION - LEVEL 2 OR GREATER
EPA CONDUCTED FCE/OFF-SITE
STATE CONDUCTED FCE / OFF-SITE
STATE INSPECTION - LEVEL 2 OR GREATER
STATE CONDUCTED FCE/ON-SITE
STATE CASE DEVELOPMENT INSPECTION: LVL 2 OR GREATR
INSPECTION BY STATE - LEVEL 2 OR GREATER
Additional Requirements
INVESTIGATIONS
National
AE-N*
AF-N
EC-N
EI-N *
SC-N
SI-N *
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS INVESTIGATION INITIATED
FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EPA INVESTIGATION CONDUCTED
EPA INVESTIGATION INITIATED
SE-R STATE INVESTIGATION CONDUCTED
SI-R STATE INVESTIGATION INITIATED
Additional Requirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reporting State PCE's are currently an option.)
REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE PCE
FEDERAL AIR TOXICS OFFSITE PCE
EPA PCE ON-SITE REVIEW
EPA 114 LETTER
EPA CONFERENCE WITH FACILITY
EPA PCE/OFF-SITE
PART 63 NOTIFICATION OF COMPLIANCE STATUS
PART 63 GRANTED COMPLIANCE DATE
PART 63 APPLICABILITY DETERMINATION
PUBLIC NOTICE BY EPA
PUBLIC HEARING BY EPA
STATE OPACITY READING
STATE COMPLAINT INSPECTION
STATE POINT INSPECTION
EMISSION INVENTORY AUDIT (PLANT VISIT)
STATE PCE ON-SITE REVIEW
STATE CONFERENCE WITH FACILITY
STATE 114 LETTER
NESHAPS SEMI-ANNUAL REPORT
EMISSION INVENTORY SUBMITTED
REPORT REVIEWED
EXECUTION AND SUBMISSION OF CM SPEC TEST RESULT
EER SUBMISSION
REVIEW OF CEM TEST RESULTS
REVIEWCEM DATA
CEM AUDIT
CEM WAIVER/ALTERNATE METHOD GRANTED
PART 63 PERIODIC REPORT
PART 63 NOTIFICATION OF COMPLIANCE STATUS
HEARING
STATE PCE OFF-SITE REVIEW
PUBLIC NOTICE BY STATE
PUBLIC HEARING BY STATE
SELF DISCLOSED VIOLATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
National
AC-N
AD-N
ES-N
EX-N
EX-N
EX-N
EX-N
EX-N
EX-N
EX-N
EX-N
PS-N
PS-N
PS-N
PS-N
PS-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
Region
TC-R
TX-R
PE-R
51-R
59-R
EX-R
MB-R
MG-R
MJ-R
R5-R
R6-R
State
13-R
43-R
44-R
DH-R
PS-R
15-R
42-R
B4-R
DJ-R
K2-R
M2-R
M3-R
M5-R
M6-R
M7-R
M8-R
ME-R
MO-R
P8-R
PX-R
S5-R
S6-R
SF-R
Additional Requirements
APPENDIX 3A -PAGE 20
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 06
STACK TESTS
National Region
State
SS-N
ST-N
2A-N
TE-N
TO-N
3A-N
3A-N
3A-N
3A-N
3A-N
3A-N
3A-N
3A-N
3A-N
3A-N
6C-N
TR-N
TS-N
SS-R
ST-R
R9-R
TE-R
53-R
09-R
16-R
21-R
63-R
65-R
75-R
91-R
92-R
MD-R
W4-R
S9-R
39-R
TS-R
REGIONAL ACTION DESCRIPTION:
EPA NON-MDR STACK TEST
AGENCY NON-MDR STACK TEST
SOURCE TEST CONDUCTED BY EPA
EPA REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
EPA REQ (O/O COND) STACK TEST/OBSV & REVIEWED
STATE REQ (O/O COND) STACK TEST OBSV & REVIEWED
NSPS PERFORMANCE TEST OBSERVED BY STATE
NESHAPS EMISSION TEST OBSERVED BY STATE
SOURCE TEST(NOT OBSERVED)
NSPS PERFORMANCE TEST OBSERVED BY EPA
NESHAPS EMISSION TEST OBSERVED BY EPA
NESHAPS EMISSION TEST NOT OBSERVED
NSPS PERFORMANCE TEST NOT OBSERVED
PART 63 PERFORMANCE TEST (OWNER OPERATOR)
STACK TEST BY COMPANY
PERFORMANCE TEST CONDUCTED BY STATE
STATE REQ (O/O COND) STACK TEST NOT OBSV BUT REVED
STATE RECEIPT OF STACK TEST REPORT
NOTICE OF VIOLATIONS
National
6A-N
6A-N
6A-N
6A-N
6A-N
6A-N
7A-N
7C-N
7C-N
7C-N
FEDERAL
National
6B-N
7E-N
7F-N
8A-N
8A-N
8A-N
8A-N
8A-N
8A-N
8A-N
AG-N
AH-N
C2-N
C3-N
Region
55-R
A9-R
C1-R
E4-R
L5-R
L6-R
Z2-R
ORDERS
Region
X3-R
N1-R
AA-R
56-R
69-R
77-R
K4-R
Y1-R
Y2-R
Y3-R
TA-R
TP-R
P1-R
State REGIONAL ACTION DESCRIPTION:
EPA NOV ISSUED
NESHAPS VIOLATION LETTER
EPA STAGE I NOV
NSPS VIOLATION LETTER
NOV ISSUED BY EPA
EPA FINDING OF VIOLATION LETTER
NOTICE OF NONCOMPLIANCE (SECTION120) ISSUED
28-R STATE NOTICE OF VIOLATION
40-R LETTER OF VIOLATION BY STATE
L1-R NOV ISSUED BY STATE
AND PENALTY AMOUNTS
State REGIONAL ACTION DESCRIPTION:
FEDERAL CONSENT DECREE ISSUED
EPA SECTION 167 ORDER ISSUED
1 13(D) APO COMPLAINT FILED
113A ORDER ISSUED
NSPS ORDER BY EPA
NESHAPS ORDER BY EPA
EPA ADMINISTRATIVE ORDER
EPA 113A SIP VIOLATION ORDER ISSUED
EPA 1 13A NON-SIP VIOLATION ORDER ISSUED
EPA 113A PROHIBIT CONSTRUCTION ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
1 13(D) APO RECALCULATED
P6-R 113(D) ADMINISTRATIVE PENALTY COLLECTED PAM1
Additional Requirements
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
Additional Requirements
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 21
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 06
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Requirements
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
CIVIL AND
X2-R STATE CONSENT DECREE ISSUED
18-R NSPS ORDER BY STATE
23-R N ES HAPS ORDE R BY STATE
29-R STATE ADMINSTRATIVE ORDER
CN-R COMPLIANCE ORDER AND NOTICE OF POTENTIAL PENALTY
SG-R STATE SETTLEMENT AGREEMENT APPROV, SIGNED & ISSUED
X1-R STATE ORDER ISSUED
Z3-R STATE ADMINISTRATIVE ORDER (W/ PENALTY)
CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N * 57-R EPA SIP CIVIL ACTION (REFERRAL)
4B-N * K3-R EPA CIVIL ACTION (REFERRAL)
4B-N * K7-R PRE-CIVIL ACTION REQUEST (REFERRAL)
5B-N * 17-R EPA CRIMINAL ACTION
5B-N * L7-R EPA CRIMINAL ACTION
7B-N * Z6-R FEDERAL CIVIL PENALTY
AI-N * TR-R FEDERAL AIR TOXICS REFERRAL TO DOJ
AJ-N TN-R NONAPPLICABILITY OF AIR TOXICS REQUIREMENTS
1D-N * L3-R CRIMINAL REFERRAL
1E-N * N2-R CIVIL REFERRAL TO STATE AG
3D-N * Z4-R STATE CIVIL PENALTY
9C-N 11-R STATE CIVIL ACTION
9C-N 19-R NSPS CIVIL ACTION BY STATE
9C-N 24-R NESHAPS CIVIL ACTION BY STATE
9C-N L2-R STATE CIVIL ACTION
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
National Region State REGIONAL ACTION DESCRIPTION: Additional Reguirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked. Comment on Day Zero documents type of
Violation
2B-N 2B-R 2B-R DAY ZERO - SHARED ENFORCEMENT LEAD PLC1 , Lead Agency
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED PLC1 , Lead Agency
2Z-N N4-R FEDERAL DAY ZERO PLC1 , Lead Agency
DB-N VO-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N V9-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N N6-R STATE DAY ZERO PLC1 , Lead Agency
NH-N NH-R NH-R NON-HPV DAY 0 PLC1 , Lead Agency
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 22
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 06
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National Region State REGIONAL ACTION DESCRIPTION:
2M-N V4-R V4-R PROP SIP OR FIP REVISION WILL LEAD TO COMPLIANCE
2M-N V6-R V6-R PROP SIP OR FIP REVISION WILL LEAD TO COMPLIANCE
OT-N OT-R OT-R OTHER ADDRESSING ACTION
6B-N X3-R FEDERAL CONSENT DECREE ISSUED
7A-N Z2-R NOTICE OF NONCOMPLIANCE (SECTION120) ISSUED
7E-N N1-R EPA SECTION 167 ORDER ISSUED
7F-N AA-R 1 1 3(D) APO COM PLAINTFILED
8A-N 56-R 113A ORDER ISSUED
8A-N 69-R NSPS ORDER BY EPA
8A-N 77-R NESHAPS ORDER BY EPA
8A-N K4-R EPA ADMINISTRATIVE ORDER
8A-N Y1-R EPA 113A SIP VIOLATION ORDER ISSUED
8A-N Y2-R EPA 113A NON-SIP VIOLATION ORDER ISSUED
8A-N Y3-R EPA 113A PROHIBIT CONSTRUCTION ORDER ISSUED
AG-N TA-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-N TP-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
2D-N X2-R STATE CONSENT DECREE ISSUED
8C-N 18-R NSPS ORDER BY STATE
8C-N 23-R NESHAPS ORDER BY STATE
8C-N 29-R STATE ADMINSTRATIVE ORDER
8C-N CN-R COMPLIANCE ORDER AND NOTICE OF POTENTIAL PENALTY
8C-N SG-R STATE SETTLEMENT AGREEMENT APPROV, SIGNED & ISSUED
8C-N X1-R STATE ORDER ISSUED
8C-N Z3-R STATE ADMINISTRATIVE ORDER (W/ PENALTY)
9C-N 11-R STATE CIVIL ACTION
9C-N 19-R NSPS CIVIL ACTION BY STATE
9C-N 24-R NESHAPS CIVIL ACTION BY STATE
9C-N L2-R STATE CIVIL ACTION
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National Region State REGIONAL ACTION DESCRIPTION:
C7-N Q5-R Q5-R CLOSEOUT MEMO ISSUED
VR-N P5-R P5-R STATE SETTLEMENT COMPLETED & PAID IN FULL
VR-N V2-R V2-R VIOLATION RESOLVED
WD-N P9-R P9-R WITHDRAWN
7G-N V3-R SOUR RET TO COMPL BY US EPA W/ NO FURTHER ACT REQ
2K-N V5-R SOUR RET TO COMPL BY STTE W/ NO FURTHER ACT REQ
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS
National Region State REGIONAL ACTION DESCRIPTION:
CC-N CC-R CC-R TITLE V ANNUAL COMPLIANCE CERT. DUE RCVD BY EPA
ER-N ER-R COMPLIANCE CERTIFICATION EPA REVIEW
CB-N CB-R TITLE V ANNUAL COMPL CERT DUE/RECVD BY STATE/LOCAL
SR-N SR-R COMPLIANCE CERTIFICATION STATE REVIEW
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
Additional Reguirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
Additional Reguirements
reguirements.)
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation, MC-in Compliance, MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Reguirements
NA-N MN-R PART 63 NEGATIVE DECLARATION OF APPLICABILITY
NM-N NM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive
APPENDIX 3A -PAGE 23
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 06
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data
Permitting Authority Name
PAFS
PAPN
Additional
FIPS Tables
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
X (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
X (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 0 Plant Lvl
X (Optional) 40 CFR Part 60 - Air Program Code 1 Plant Lvl
SPT1 APC1=8
SPT1 APC1=M
SPT1 APC1=0
SPT1 APC1=1
X
X
X
X
X
APPENDIX 3A -PAGE 24
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 07
FULL COMPLIANCE EVALUATIONS (FCE)
National
AA-N
AB-N
FE-N
FZ-N
FF-N
FS-N
Region
JA-R
JB-R
AE-R
AZ-R
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE FCE
FEDERAL AIR TOXICS OFFSITE FCE
EPA CONDUCTED FCE/ ON-SITE
EPA CONDUCTED FCE/ OFF-SITE
AF-R STATE CONDUCTED FCE/ OFF-SITE
AS-R STATE CONDUCTED FCE/ ON-SITE
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
Region
JE-R
JF-R
II-R
IE-R
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS INVESTIGATION INITIATED
FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EPA INVESTIGATION CONDUCTED
EPA INVESTIGATION STARTED
IC-R STATE INVESTIGATION CONDUCTED
IS-R STATE INVESTIGATION STARTED
Additional Reguirements
Additional Reguirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reporting State PCE's are currently an option.)
National
AC-N
AD-N
EE-N
EM-N
EO-N
EP-N
ES-N
ES-N
ES-N
EX-N
PC-N
PO-N
PP-N
PR-N
PS-N
PX-N
PX-N
PX-N
PX-N
PX-N
Region
JC-R
JD-R
AG-R
AL-R
AB-R
AK-R
AC-R
M4-R
M6-R
AD-R
State
AU-R
AT-R
AV-R
AW-R
AP-R
AX-R
UD-R
UT-R
WX-R
WY-R
STACK TESTS
National Region
State
2A-N
2A-N
TE-N
TO-N
TT-N
3A-N
6C-N
TR-N
TS-N
A8-R
A9-R
AN-R
AO-R
AY-R
B1-R
A7-R
AR-R
AQ-R
REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE PCE
FEDERAL AIR TOXICS OFFSITE PCE
COMPLAINT ON-SITE PCE (EPA)
PROCESS OFF-SITE PCE (EPA)
ON-SITE PCE OBSERVATION (EPA)
PERMIT ON-SITE PCE (EPA)
EPA CONDUCTED PCE/ ON-SITE
CEM SYSTEM TEST AUDIT
ACID RAIN CEM SYSTEM REVIEW
EPA CONDUCTED PCE/ OFF-SITE
COMPLAINT ON-SITE PCE (STATE)
ON-SITE PCE OBSERVATION (STATE)
PERMIT ON-SITE PCE (STATE)
PROCESS OFF-SITE PCE (STATE)
STATE CONDUCTED PCE/ ON-SITE
STATE CONDUCTED PCE/ OFF-SITE
TV MONITORING REPORT DUE/RECEIVED
TV MONITORING REPORT REVIEWED BY STATE
EMISSION INVENTORY DUE/RECEIVED
EMISSION INVENTORY REVIEWED BY STATE
REGIONAL ACTION DESCRIPTION:
EPA SOURCE TEST
SOURCE TEST OBSERVED BY EPA
EPA REQ (O/O COND) STACK TEST/NOT OBSVD BUT REVWD
EPA REQ (O/O COND) STACK TEST/OBSERVED & REVIEWED
EPA RECEIPT OF STACK TEST REPORT
SOURCE TEST OBSERVED BY STATE
STATE STACK TEST
STATE REQ (O/O COND) STACK TEST/NOT OBSVD BUT REVD
STATE RECEIPT OF STACK TEST REPORT
Additional Reguirements
Additional Reguirements
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 25
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING:
NOTICE OF VIOLATIONS
National Region State REGIONAL ACTION DESCRIPTION:
REGION 07
6A-N
6A-N
6A-N
6A-N
7A-N
7C-N
7C-N
7C-N
7C-N
7C-N
FEDERAL
L4-R
LV-R
LW-R
X9-R
LO-R
G5-R
GG-R
NOV ISSUED BY EPA
LETTER OF VIOLATION
LOW - LETTER OF WARNING
FINDING OF VIOLATION-EPA
NOTICE OF NON-COMPLIANCE
NOV ISSUED BY STATE
LOCAL NOV
WE-R OPEN BURNING -NOTICE OF VIOLATION ISSUED
ORDERS
WF-R
XB-R
AND
NOTICE OF VIOLATION ISSUED, ERP REQUESTED
LETTER OF VIOLATION-STATE
PENALTY AMOUNTS
Additional Requirements
6B-N
7E-N
7F-N
8A-N
8A-N
8A-N
8A-N
AG-N
AH-N
C2-N
C3-N
FEDERAL COURT DECREE ISSUED
EPA SECTION 167 ORDER
113(D) ADMINISTRATIVE CIVIL COMPLAINT FILED
113 ORDER ISSUED
113 ORDER REVISED
EPA 113A SIP VIOLATION ORDER ISSUED
EPA 113A NON-SIP VIOLATION ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
113(D) PENALTY RECALCULATED
113(D) ADMINISTRATIVE PENALTY COLLECTED
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
G9-R STATE CONSENT AGREEMENT ISSUED
H3-R STATE COURT DECREE ISSUED
G6-R STATE ORDER ISSUED
G7-R REVISED STATE ORDER
GE-R SETTLEMENT AGREEMENT
GZ-R STATE ORDER FINAL ASSESSED CASH PENALTY
WD-R ENFORCEMENT ORDER ISSUED BY COUNTY LOCAL PROGRAM
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N
5B-N
7B-N
AI-N
AJ-N
1D-N
1E-N
1E-N
1E-N
3D-N
9C-N
EPA CIVIL ACTION (REFERRAL)
EPA CRIMINAL ACTION
EPA CIVIL PENALTY
FEDERAL AIR TOXICS REFERRAL TO DOJ
NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
H5-R STATE CRIMINAL ACTION
CK-R MACC PERMISSION TO REFER TO MO AG
GA-R STATE CIVIL REFERAL TO ST ATTORNEY GENERAL
GL-R CIVIL REFERRAL TO CITY/LOCAL GOVERNMENT ATTORNEY
H4-R STATE CIVIL PENALTY
H2-R CIVIL ACTION BY STATE
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 26
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 07
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
Violation
2B-N
OB-R OB-R DAY ZERO-SHARED ENFORCEMENT LEAD
2U-N OU-R OU-R DAY ZERO-ENFORCEMENT LEAD IS UNASSIGNED
2Z-N DO-R FEDERAL DAY ZERO
DB-N OS-R LEAD CHANGES TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N CI-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N CO-R STATE DAY ZERO
PLC1, Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National
2M-N
OT-N
6B-N
7A-N
7E-N
7F-N
8A-N
8A-N
8A-N
8A-N
AG-N
AH-N
2D-N
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
9C-N
Region State REGIONAL ACTION DESCRIPTION:
CF-R CF-R PROP SIP OR FIP REVISION WILL LEAD TO COMPLIANCE
OT-R OT-R OTHER ADDRESSING ACTION
L6-R FEDERAL COURT DECREE ISSUED
LO-R NOTICE OF NON-COMPLIANCE
EA-R EPA SECTION 167 ORDER
LP-R 1 13(D) ADMINISTRATIVE CIVIL COMPLAINT FILED
E1-R 113 ORDER ISSUED
E3-R 113 ORDER REVISED
E4-R EPA 113A SIP VIOLATION ORDER ISSUED
E5-R EPA 1 13A NON-SIP VIOLATION ORDER ISSUED
JG-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
JH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
G9-R STATE CONSENT AGREEMENT ISSUED
H3-R STATE COURT DECREE ISSUED
G6-R STATE ORDER ISSUED
G7-R REVISED STATE ORDER
GE-R SETTLEMENT AGREEMENT
GZ-R STATE ORDER FINAL ASSESSED CASH PENALTY
WD-R ENFORCEMENT ORDER ISSUED BY COUNTY LOCAL PROGRAM
H2-R CIVIL ACTION BY STATE
Additional Reguirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National
C7-N
VR-N
WD-N
7G-N
C3-N
2K-N
TITLE V
National
CC-N
ER-N
CB-N
SR-N
SR-N
Region State REGIONAL ACTION DESCRIPTION:
C7-R C7-R CLOSEOUT MEMO ISSUED
CD-R CD-R VIOLATION RESOLVED
CB-R CB-R 113(D) WITHDRAWN
CE-R SOUR RET TO COMPL BY US EPA W/ NO FURTHER ACT REQ
LK-R 1 13(D) ADMINISTRATIVE PENALTY COLLECTED
HB-R SOUR RET TO COMPL BY STATE WITH NO FURTHER ACT REQ
SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS
Region State REGIONAL ACTION DESCRIPTION:
UC-R UC-R TITLE V COMPLIANCE CERT DUE/RECEIVED BY EPA
UE-R COMPLIANCE CERTIFICATION EPA REVIEW
UB-R TITLE V COMPLIANCE CERT. DUE/RECEIVED BY ST/LOCAL
SR-R TITLE V COMPLIANCE CERTIFICATION REVIEW BY STATE
US-R COMPLIANCE CERTIFICATION STATE REVIEW
Additional Reguirements
reguirements.)
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation, MC-in Compliance, MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 27
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 07
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data Additional
Permitting Authority Name FIPS Tables
PAFS
PAPN
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
SPT1APC1=8 X X (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
SPT1 APC1 =M XX (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
SPT1 APC1 =0 XX (Optional) 40 CFR Part 60 - Air Program Code 0 Plant Lvl
SPT1 APC1=1
X X (Optional) 40 CFR Part 60 - Air Program Code 1
Plant Lvl
APPENDIX 3A -PAGE 28
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 07
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
NA-N PA-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NM-N PM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N PN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 07
Additional Requirements
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data
Permitting Authority Name
PAFS
PAPN
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
Additional
FIPS Tables
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1APC1=9 X X (Optional)
SPT1APC1=8 X X (Optional)
SPT1APC1=M X X (Optional)
SPT1APC1=0 X X (Optional)
SPT1APC1=1 X X (Optional)
40 CFR Part 60 (NSPS) Subparts- Air Program Code 9
40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8
40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M
40 CFR Part 60 - Air Program Code 0
40 CFR Part 60 - Air Program Code 1
Plant Lvl
Plant Lvl
Plant Lvl
Plant Lvl
Plant Lvl
APPENDIX 3A -PAGE 29
-------
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 30
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 08
FULL COMPLIANCE EVALUATIONS (FCE)
National Region State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE FCE
FEDERAL AIR TOXICS OFFSITE FCE
EPA CONDUCTED FCE/ON-SITE
EPA CONDUCTED FCE/OFF-SITE
FF-R STATE CONDUCTED FCE/OFF-SITE
FS-R STATE CONDUCTED FCE/ON-SITE
AA-N
AB-N
FE-N
FZ-N
FF-N
FS-N
Additional Requirements
INVESTIGATIONS
National Region
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS INVESTIGATION INITIATED
FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EPA INVESTIGATION CONDUCTED
EPA INVESTIGATION STARTED
SC-R STATE INVESTIGATION CONDUCTED
SI-R STATE INVESTIGATION STARTED
Additional Requirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reporting State PCE's are currently an option.)
National
AC-N
AD-N
ES-N
EX-N
PS-N
PX-N
GC-R
GD-R
ES-R
EX-R
STACK TESTS
National
SS-N
TE-N
TO-N
TT-N
3A-N
ST-N
TR-N
TS-N
Region
SS-R
TE-R
TO-R
TT-R
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE PCE
FEDERAL AIR TOXICS OFFSITE PCE
EPA PCE/ON-SITE
EPA PCE/OFF-SITE
PS-R STATE PCE/ON-SITE
PX-R STATE PCE/OFF-SITE
State REGIONAL ACTION DESCRIPTION:
EPA NON-MDR STACK TEST
EPA REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
EPA REQ (O/O COND) STACK TEST/OBSERVED & REVIEWED
EPA RECEIPT OF STACK TEST REPORT
3A-R STATE REQ (O/O COND) STACK TEST/OBSV & REVIEWED
ST-R AGENCY NON-MDR STACK TEST
TR-R STATE REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
TS-R STATE RECEIPT OF STACK TEST REPORT
Additional Requirements
NOTICE OF VIOLATIONS
National Region State
6A-N L5-R
7A-N Z2-R
7C-N L1-R
FEDERAL ORDERS AND PENALTY AMOUNTS
REGIONAL ACTION DESCRIPTION:
NOV ISSUED BY EPA
NOTICE OF NON-COMPLIANCE
NOV ISSUED BY STATE
National
6B-N
7E-N
7F-N
8A-N
8A-N
8A-N
AG-N
AH-N
C2-N
C3-N
Region
X3-R
K1-R
AF-R
57-R
Y1-R
Y2-R
GG-R
GH-R
AD-R
A3-R
State REGIONAL ACTION DESCRIPTION:
FEDERAL CONSENT DECREE ISSUED
EPA 167 PSD ORDER
1 13 (D) ADMINISTRATIVE COMPLAINT FILED
EPA ABATEMENT ORDER ISSUED
EPA ADMINISTRATIVE ORDER ISSUED
EPA 1 13A NON-SIP VIOLATION ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
1 13(D) APO RECALCULATED
1 13(D) ADMINISTRATIVE PENALTY COLLECTED
Additional Reguirements
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).
Additional Reguirements
Additional Reguirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A-PAGE 31
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 08
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N
8C-N
8C-N
X2-R STATE COURT DECREE ISSUED
25-R STATE CONSENT AGREEMENT ISSUED
X1-R STATE ORDER ISSUED
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
EPA CIVIL ACTION_(REFERRAL)
EPA CRIMINAL ACTION
EPA PENALTY SETTLEMENT
FEDERAL AIR TOXICS REFERRAL TO DOJ
NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
L3-R STATE CRIMINAL ACTION
K2-R CIVIL REFERRAL TO STATE ATT. GENERAL
Z4-R STATE ADMINISTRATIVE PENALTY SETTLEMENT
L2-R CIVIL ACTION BY STATE
4B-N
5B-N
7B-N
AI-N
AJ-N
1D-N
1E-N
3D-N
9C-N
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
Violation
2B-N
2B-R 2B-R DAY ZERO-SHARED ENFORCEMENT LEAD
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED
2Z-N 60-R FEDERAL DAY ZERO
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N EL-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N 64-R STATE DAY ZERO
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National Region State REGIONAL ACTION DESCRIPTION:
2M-N
OT-N
6B-N
7A-N
7E-N
7F-N
8A-N
8A-N
8A-N
AG-N
AH-N
2D-N
8C-N
8C-N
9C-N
V5-R PROPOSED SIP OR FIP REVISE WILL LEAD TO COMPLIANCE
OT-R OTHER ADDRESSING ACTION
FEDERAL CONSENT DECREE ISSUED
NOTICE OF NON-COMPLIANCE
EPA 167 PSD ORDER
113 (D) ADMINISTRATIVE COMPLAINT FILED
EPA ABATEMENT ORDER ISSUED
EPA ADMINISTRATIVE ORDER ISSUED
EPA 113A NON-SIP VIOLATION ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
X2-R STATE COURT DECREE ISSUED
25-R STATE CONSENT AGREEMENT ISSUED
X1-R STATE ORDER ISSUED
L2-R CIVIL ACTION BY STATE
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National
C7-N
VR-N
WD-N
7G-N
C3-N
2K-N
State REGIONAL ACTION DESCRIPTION:
DC-R CLOSEOUT MEMO ISSUED
V2-R VIOLATION RESOLVED
AW-R WITHDRAWAL
SOURCE RET TO COMPL BY EPA W/ NO FURTHER ACT REQ
113(D) ADMINISTRATIVE PENALTY COLLECTED
V4-R SOURCE RET TO COMPL BY STATE W/ NO FURTHER ACT REQ
PLC1,Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
Additional Requirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
Additional Requirements
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 32
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 08
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS requirements.)
National
CC-N
ER-N
CB-N
SR-N
State REGIONAL ACTION DESCRIPTION:
CC-R TITLE V COMPLIANCE CERT. DUE/RECEIVED BY EPA
COMPLIANCE CERTIFICATION EPA REVIEW
CB-R
VS-R
TV ANN COMPLIANCE CERT DUE/RECVD BY STATE/LOCAL
COMPLIANCE CERTIFICATION STATE REVIEW
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
NA-N NA-R EPA MACT FCE/PCE NON-APPLICABILITY DETERMINATION
NM-N NM-R EPA MACT NON-APPLICABLE DETERM FOR INVESTIGATIONS
NN-N NN-R EPA NSR/PSD NON-APPLICABLE DETERMINE-INVESTIGATION
Additional Requirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation,MC-in Compliance,MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Requirements
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data
Permitting Authority Name
PAFS
PAPN
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
Additional
FIPS Tables
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1APC1=9 X X (Optional)
SPT1APC1=8 X X (Optional)
SPT1APC1=M X X (Optional)
SPT1APC1=0 X X (Optional)
SPT1APC1=1 X X (Optional)
40 CFR Part 60 (NSPS) Subparts- Air Program Code 9
40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8
40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M
40 CFR Part 60 - Air Program Code 0
40 CFR Part 60 - Air Program Code 1
Plant Lvl
Plant Lvl
Plant Lvl
Plant Lvl
Plant Lvl
APPENDIX 3A -PAGE 33
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 09
FULL COMPLIANCE EVALUATIONS (FCE)
National
AA-N
AB-N
FE-N
FZ-N
FF-N
FF-N
FS-N
FS-N
Region
EA-R
EB-R
BX-R
BY-R
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE FCE
FEDERAL AIR TOXICS OFFSITE FCE
FULL COMPLIANCE EVALUATION BY EPA
FULL COMPLIANCE EVALUATION OFFSITE BY EPA
JX-R FULL COMPLIANCE EVALUATION OFFSITE BY STATE
RX-R FULL COMPLIANCE EVALUATION OFFSITE BY LOCAL
JY-R FULL COMPLIANCE EVALUATION BY STATE
RY-R FULL COMPLIANCE EVALUATION BY LOCAL - ONSITE
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SC-N
SI-N *
SI-N *
Region
EE-R
EF-R
CE-R
CD-R
State REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS INVESTIGATION INITIATED
FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EPA INVESTIGATION CONDUCTED
EPA INVESTIGATION STARTED
LD-R STATE INVESTIGATION CONDUCTED
UD-R LOCAL INVESTIGATION CONDUCTED
LC-R STATE INVESTIGATION STARTED
UC-R LOCAL INVESTIGATION STARTED
Additional Reguirements
Additional Reguirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reporting State PCE's are currently an option.)
National
AC-N
AD-N
ES-N
EX-N
PS-N
PS-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
Region State
EC-R
ED-R
CJ-R
CK-R
JV-R
RV-R
IL-R
JW-R
JZ-R
LE-R
LF-R
LG-R
NT-R
NV-R
RC-R
RW-R
SQ-R
SS-R
ST-R
SU-R
TT-R
TV-R
REGIONAL ACTION DESCRIPTION:
FEDERAL AIR TOXICS ONSITE PCE
FEDERAL AIR TOXICS OFFSITE PCE
EPA PARTIAL INSPECTION ON-SITE
EPA PARTIAL INSPECTION OFF-SITE
PARTIAL ONSITE VISIT BY STATE
PARTIAL ONSITE VISIT BY LOCAL
STATE CEM, EER, TEST DATA REVIEW
PARTIAL OFFSITE REVIEW BY STATE
RATA - STATE
REVIEWED THROUGHPUT REPORTS-STATE
REVIEWED ANNUAL EMISSION SUMMARY REPORTS-STATE
REVIEWED BREAKDOWN/EXCESS EMISSIONS REPORTS-STATE
SEMI-ANNUAL TITLE V CERTIFICATION RCVD - STATE
QUARTERLY TITLE V CERTIFICATION RECEIVED - STATE
PARTIAL OFFSITE REVIEW/LOCAL (INTERIM TOWARDS FCE)
PARTIAL OFFSITE REVIEW BY LOCAL
RATA - DISTRICT
REVIEWED ANNUAL THROUGHPUT REPORTS-DISTRICT
REVIEWED ANNUAL EMISSION SUMMARY REPORTS-DISTRICT
REVIEWED BREAKDOWN/EXCESS EMISSIONS REPORTS-DISTR.
SEMI-ANNUAL TITLE V CERT RECEIVED - DISTRICT
QUARTERLY TITLE V CERTIFICATION RECEIVED - STATE
Additional Reguirements
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 34
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 09
STACK TESTS
National Region State REGIONAL ACTION DESCRIPTION:
SOURCE TEST WITNESSED BY EPA
EPA REVIEWS A SOURCE TEST
EPA OBSERVED SOURCE TEST
STATE SOURCE TEST OBSERVED
DISTRICT REQ(O/O COND) SRCE TEST OBSERVD & REVIEWD
SOURCE TEST CONDUCTED BY STATE
DISTRICT SOURCE TEST CONDUCTED
LOCAL SOURCE TEST_CONDUCTED
SOURCE TEST REVIEW BY STATE
SOURCE TEST REVIEW BY LOCAL
2A-N
TE-N
TO-N
3A-N
3A-N
6C-N
6C-N
6C-N
TR-N
TR-N
AL-R
CI-R
CH-R
IK-R
RZ-R
JU-R
RJ-R
RU-R
JT-R
RT-R
NOTICE OF VIOLATIONS
National Region State
6A-N
7A-N
7C-N
7C-N
BB-R
B2-R
J8-R
S8-R
REGIONAL ACTION DESCRIPTION:
EPA NOV ISSUED
EPA SECTION 120 NOTICE OF NONCOMPLIANCE
STATE NOV ISSUED
DISTRICT NOV ISSUED
FEDERAL ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
EPA CONSENT DECREE
EPA SECTION 167 ORDER ISSUED
EPA SECTION (D) PENALTY ORDER FILED
EPA 113(D) ADMINISTRATIVE COMPLAINT
NOTICE OF DETERMINATION ISSUED
EPA 113 ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
113D APO PENALTY RECALCULATED
113D APO PENALTY COLLECTED
6B-N
7E-N
7F-N
7F-N
7F-N
8A-N
AG-N
AH-N
C2-N
C3-N
BT-R
BO-R
BE-R
BF-R
C4-R
BC-R
EG-R
EH-R
BK-R
BL-R
Additional Requirements
Results Code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
Additional Requirements
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
STATE ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
Note: Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
Additional Requirements
2D-N
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
JK-R STATE CONSENT DECREE
SK-R DISTRICT CONSENT DECREE
J4-R STATE NON ORDER REQUIRES COMPLIANCE
JE-R STATE ADMINISTRATIVE COMPLAINT ORDER
JG-R STATE MS HEARING ORDERS COMPLIANCE
JH-R STATE ABATEMENT ORDER
JP-R STATE LETTER ORDERS COMPLIANCE
S4-R LOCAL NON ORDER REQUIRES COMPLIANCE
SE-R LOCAL ADMINISTRATIVE COMPLAINT ORDER
SG-R LOCAL MS HEARING ORDERS COMPLIANCE
SH-R DISTRICT ABATEMENT ORDER
SP-R LOCAL LETTER ORDERS COMPLIANCE
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 35
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 09
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
Region State REGIONAL ACTION DESCRIPTION:
EPA CIVIL ACTION_(REFERRAL)
EPA CRIMINAL ACTION
EPA CIVIL PENALTY ASSESSED
FEDERAL AIR TOXICS REFERRAL TO DOJ
NONAPPLICABILITY OF AIR TOXIC REQUIREMENTS
STATE CRIMINAL ACTION
DISTRICT CRIMINAL ACTION
STATE REFERRAL TO ATTORNEY GENERAL
DISTRICT CIVIL REFERRAL TO AG
STATE CIVIL PENALTY
DISTRICT CIVIL PENALTY ASSESSED
STATE CIVIL ACTION
DISTRICT CIVIL ACTION
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Requirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
Violation
2B-N CB-R CB-R DAY ZERO - SHARED ENFORCEMENT LEAD
2U-N CC-R CC-R DAY ZERO-ENFORCEMENT LEAD IS UNASSIGNED
2Z-N B5-R EPA "DAY ZERO" (STARTS SV CLOCK)
DB-N CA-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N CO-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N B9-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N J9-R DAY ZERO BY STATE FOR AN SV
2E-N S9-R DISTRICT DAY 0 FOR SV
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National Region State REGIONAL ACTION DESCRIPTION:
PLC1, Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
2M-N
2M-N
2M-N
OT-N
OT-N
OT-N
6B-N
7A-N
7E-N
7F-N
7F-N
7F-N
8A-N
AG-N
AH-N
2D-N
2D-N
2L-N
2L-N
2L-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
9C-N
9C-N
DO-R
AS-R PROPOSED SIP/FIP REVISION TO COMPLIANCE
DP-R FIP REVISION
MO-R STATE SIP REVISION
OTHER EPA ADDRESSING ACTION
JR-R OTHER STATE ADDRESSING ACTION
SR-R OTHER DISTRICT ADDRESSING ACTION
EPA CONSENT DECREE
EPA SECTION 120 NOTICE OF NONCOMPLIANCE
EPA SECTION 167 ORDER ISSUED
EPA SECTION (D) PENALTY ORDER FILED
EPA 113(D) ADMINISTRATIVE COMPLAINT
NOTICE OF DETERMINATION ISSUED
EPA 113 ORDER ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
JK-R STATE CONSENT DECREE
SK-R DISTRICT CONSENT DECREE
EPA ISSUES SOURCE SPECIFIC REV
IO-R STATE PROPOSED SIP REVISION
RN-R DISTRICT SIP REVISION LEADS TO COMPLIANCE
J4-R STATE NON ORDER REQUIRES COMPLIANCE
JE-R STATE ADMINISTRATIVE COMPLAINT ORDER
JG-R STATE MS HEARING ORDERS COMPLIANCE
JH-R STATE ABATEMENT ORDER
JP-R STATE LETTER ORDERS COMPLIANCE
S4-R LOCAL NON ORDER REQUIRES COMPLIANCE
SE-R LOCAL ADMINISTRATIVE COMPLAINT ORDER
SG-R LOCAL MS HEARING ORDERS COMPLIANCE
SH-R DISTRICT ABATEMENT ORDER
SP-R LOCAL LETTER ORDERS COMPLIANCE
JI-R STATE CIVIL ACTION
SI-R DISTRICT CIVIL ACTION
PLC1,Lead Agency
PLC1,Lead Agency
Additional Requirements
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
PAM1
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 36
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 09
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National
VR-N
VR-N
VR-N
WD-N
7G-N
C3-N
2K-N
2K-N
Region
BV-R
BG-R
A8-R
BL-R
State REGIONAL ACTION DESCRIPTION:
EPA SV RESOLVED
JO-R STATE SV RESOLVED
SO-R DISTRICT SV RESOLVED
BG-R EPA SECTION 1 13 (D) ACTION WITHDRAWN
SOURCE RETURNED TO COMPLIANCE NFA (EPA)
1 13D APO PENALTY COLLECTED
I7-R STATE COMPLIANCE NFA
R7-R LOCAL COMPLIANCE NFA
Additional Requirements
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS requirements.)
National Region
CC-N CG-R
ER-N CF-R
CB-N
CB-N
SR-N
SR-N
JQ-R
State REGIONAL ACTION DESCRIPTION:
EPA TITLE V CERTIFICATION DUE/RECEIVED
EPA TITLE V CERTIFICATION REVIEW
TV ANNUAL COMPL. CERT DUE/RECVD BY STATE
RR-R TV ANNUAL COMPLIANCE CERT DUE/RECVD BY DISTRICT
JS-R TITLE V CERTIFICATION REVIEW - STATE
RS-R TITLE V CERTIFICATION REVIEW- LOCAL
NON-APPLICABILITY DETERMINATIONS
National Region State REGIONAL ACTION DESCRIPTION:
NA-N CP-R APPLICABLE MACT
NM-N CQ-R NON-APPLICABLE MACT
Additional Requirements
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation,MC-in Compliance,MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
Additional Reguirements
Title V Permit Program Data Elements and Events
AFS Acronym Region Use State Use Description-Data Additional
Permitting Authority Name FIPS Tables
PAFS
PAPN
APC1
PLAP
SCA1
DP
DQ
PP
PM
PE
IF
IM
IR
PO
PL
PG
PH
PT
PD
PQ
AFS Plant ID Number
Permit Number
Permit Air Program Code
Permit Pollutant Code
Permit Program Compliance
Draft Permit
Draft Permit Modification
Date Permit Reed By EPA
Date Permit Mod Reed by EPA
EPA 45-Day Review Period
Date Permit Issued
Date Permit Modification Issued
Permit Renewal
Date EPA Objects to Permit
Date EPA Objects to Permit Mod
Date EPA Denies Revised Permit
Date EPA Denies Revised Mod
Date Public Petitions EPA
Date Public Petitions EPA - Mod
Date EPA Action - Public Petition
V
Facil
Current
Permit Number
System Generated
Note: please reference http://www.epa.aov/compliance/resources/publications/data/svstems/air/pmtpolcv.pdffor more information on the reporting of
Title V data.
Data Elements for Subparts
AFS Acronym Region State Use Description-Data Elements Additional
SPT1 APC1 =9 XX (Optional) 40 CFR Part 60 (NSPS) Subparts- Air Program Code 9 Plant Lvl
SPT1 APC1 =8 XX (Optional) 40 CFR Part 61 (NonMACT NESHAP) Subparts-Air Program Code 8 Plant Lvl
SPT1APC1=M X X (Optional) 40 CFR Part 63 (MACT NESHAP) Subparts-Air Program Code M Plant Lvl
SPT1APC1=0 X X (Optional) 40 CFR Part 60-Air Program Code 0 Plant Lvl
SPT1APC1=1 X X (Optional) 40 CFR Part 60-Air Program Code 1 Plant Lvl
APPENDIX 3A -PAGE 37
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 10
FULL COMPLIANCE EVALUATIONS (FCE)
National
AA-N
AB-N
FE-N
FE-N
FZ-N
FF-N
FF-N
FS-N
FS-N
FS-N
FS-N
Region State REGIONAL ACTION DESCRIPTION:
AA-R FEDERAL AIR TOXICS ONSITE FCE
AB-R FEDERAL AIR TOXICS OFFSITE FCE
2Y-R EPA MULTIMEDIA FCE - ONSITE
FE-R EPA CONDUCTED FULL COMPLIANCE EVALUATION/ ON-SITE
FZ-R EPA CONDUCTED FULL COMPLIANCE EVALUATION/OFF-SITE
1A-R AK-CONDUCTED FULL COMPLIANCE EVALUATION - OFFSITE
FF-R STATE/LOCAL CONDUCTED FCE / OFF-SITE
2C-R AK-CONDUCTED FULL COMPLIANCE EVALUATION - ONSITE
CC-R OR STATE INSPEC-COMMITTED COMPREHEN. COMP. ON-SITE
CN-R OREGON STATE INSPEC-NONCOM COMPREHEN. COMP ON-SITE
FS-R STATE/LOCAL CONDUCTED FCE - ONSITE
Additional Reguirements
INVESTIGATIONS
National
AE-N *
AF-N
EC-N
EI-N *
SC-N
SI-N *
Region State REGIONAL ACTION DESCRIPTION:
AE-R FEDERAL AIR TOXICS INVESTIGATION INITIATED
AF-R FEDERAL AIR TOXICS INVESTIGATION COMPLETED
EC-R EPA INVESTIGATION CONDUCTED
EI-R EPA INVESTIGATION INITIATED
SC-R STATE/LOCAL INVESTIGATION CONDUCTED
SI-R STATE/LOCAL INVESTIGATION INITIATED
Additional Reguirements
PARTIAL COMPLIANCE EVALUATIONS (PCE)-(Note: reportina State PCE's are currently an ODtion.)
National
AC-N
AD-N
ES-N
ES-N
EX-N
EX-N
PS-N
PX-N
PX-N
PX-N
PX-N
PX-N
PX-N
Region State REGIONAL ACTION DESCRIPTION:
AC-R FEDERAL AIR TOXICS ONSITE PCE
AD-R FEDERAL AIR TOXICS OFFSITE PCE
2F-R EPA-MULTIMEDIA PCE/ON-SITE
ES-R EPA PARTIAL COMPLIANCE EVALUATION ON-SITE
ED-R EPA PARTIAL COMPLIANCE EVALUATION- SELF DISCLOSURE
EX-R EPA PARTIAL COMPLIANCE EVALUATION OFF-SITE
PS-R STATE/LOCAL PARTIAL COMPLIANCE EVALUATION - ONSITE
6A-R AK-FACILITY OPRPT-THOROUGH REVIEW PCE OFFSITE
80-R AK-PREAPP. LIMIT FUEL USAGE REPORT - PCE/OFFSITE
81 -R AK-ORL ANNUAL COMPLIANCE CERT - PCE OFFSITE
83-R AK-SEMI-ANN. OPRPT/GENERAL PERMIT/PCE OFFSITE
99-R AK-ANNUAL COMPLIANCE CERTIFICATION - PCE/OFFSITE
PX-R STAE/LOCAL PARTIAL COMPLIANCE EVALUATION - OFFSITE
Additional Reguirements
STACK TESTS
National
SS-N
TE-N
TO-N
3A-N
ST-N
TR-N
TR-N
Region State REGIONAL ACTION DESCRIPTION:
SS-R EPA NON-MDR STACK TEST
TE-R EPA REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
TO-R EPA REQD (/O COND) STACK TEST/OBSERVED & REVIEWED
23-R S/L REQD (O/O CONDUCTED) STACK TEST OBSV & REVIEWD
SL-R AGENCY NON-MDR STACK TEST
59-R AK-STACK TEST REQ (O/O COND) NOT OBSV BUT REVIEWED
TR-R S/L REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
Additional Reguirements
Results code:Pass(PP) or Fail(FF).Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results Code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF) .Action PLLT.
Results code:Pass(PP) or Fail(FF).
Results code:Pass(PP) or Fail(FF).
NOTICE OF VIOLATIONS
National
6A-N
6A-N
7A-N
7C-N
7C-N
7C-N
7C-N
7C-N
State
2N-R
84-R
91-R
96-R
L1-R
REGIONAL ACTION DESCRIPTION:
FINDING A VIOLATION
NOV ISSUED BY EPA
EPA NOTICE OF NON-COMPLIANCE (SECTION 120)
NWAPA/WA -WARNING LETTER
IDAHO-NOV ISSUED
LOCAL AGENCY NOTICE OF VIOLATION
OR - NOTICE OF NON-COMPLIANCE
NOV ISSUED BY STATE
Additional Reguirements
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 38
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING:
FEDERAL ORDERS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
REGION 10
6B-N
6B-N
7E-N
7F-N
8A-N
AG-N
AH-N
12-R FEDERAL CONSENT AGREEMENT SIGNED
X3-R FEDERAL COURT DECREE ISSUED
60-R 1 67 STOP CONSTRUCTION ORDER
7F-R 113DAPO COMPLAINT FILED.
78-R COMPLIANCE ORDER 113 FINAL/ISSUED
AG-R FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
AH-R FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
STATE ORDERS AND PENALTY AMOUNTS
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
Additional Requirements
Note: Administrative Orders include Penalty Notices,Compliance Notices, Agreed Orders,Compliance Administrative Orders, Consent Orders or Final Orders
2D-N 9A-R PSCAA/WA-JUDICIAL REFERRAL
2D-N LA-R STATE CONSENT AGREEMENT ISSUED
2D-N X2-R STATE COURT ORDER ISSUED
8C-N 09-R WA-CIVIL PENALTIES(FORMAL ENFORCE DOC W/PENALTIES)
8C-N 13-R PSCAA/WA-ASSURANCE OF DISCONTINUANCE
8C-N 2G-R WA/CRO - NOTICE OF PENALTY
8C-N 2P-R NWAPA/WA - IMPOSITION OF PENALTY
8C-N 2Q-R NWAPA/WA-ASSURANCE OF DISCONTINUANCE
8C-N 2R-R SCAPCA/WA-NOTICE & ORDER OF ASSESSMENT
8C-N 37-R AK-COMPLIANCE ORDERS BY CONSENT (COBC)
8C-N 61-R IDAHO-CONSENT ORDER ISSUED
8C-N 7D-R ALASKA-SETTLEMENT AGREEMENT
8C-N 93-R MUTUAL AGREEMENTS ORDER (MAO)
8C-N 94-R OREGON DEPARTMENT ORDER
8C-N 97-R OREGON CIVIL PENALTY
8C-N 9F-R ORCAA-NOTICE OF CIVIL PENALTY ASSESSMENT
8C-N A1-R ALASKA - NUISANCE ABATEMENT ORDER
8C-N A2-R ALASKA-EMERGENCY ORDER
8C-N IN-R WDOE/ERO ISSUANCE OF NOTICE OF PENALTY ACTION
8C-N X1-R STATE ORDER ISSUED
8C-N X4-R ID-NOVW/PENALTY-RESOLVES W/O CONCENT ORDER OR CIV
8C-N XI-R 113(A)(1)SIP ORDER ISSUED BY STATE
CIVIL AND CRIMINAL REFERRALS AND PENALTY AMOUNTS
National Region State REGIONAL ACTION DESCRIPTION:
4B-N * 22-R REFER TO JUSTICE DEPARTMENT
4B-N * L6-R EPA CIVIL ACTION (REFERRAL)
AI-N * AI-R FEDERAL AIR TOXICS REFERRAL TO DOJ
AJ-N AJ-R NONAPPLICABILITY OF AIR TOXIC REQUIREMENT
1D-N * L3-R STATE CRIMINAL ACTION
1E-N * LB-R STATE CIVIL REFERAL TOST ATTORNEY GENERAL
3D-N * 88-R STATE CIVIL PENALTY ASSESSMENT
9C-N * 11-R PSCAA/WA-INJUNCTIVE RELIEF
9C-N L2-R CIVIL ACTION BY STATE
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
Additional Requirements
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - DAY ZERO AND LEAD CHANGES
National Region State REGIONAL ACTION DESCRIPTION: Additional Reguirements
Note: HPV cases contain a Day Zero action, Date Addressed, formal or informal action and Date Resolved. Any action can be linked.Comment on Day Zero documents type of
PLC1,Lead Agency
PLC1,Lead Agency
PLC1,Lead Agency
2B-N 2B-R 2B-R DAY ZERO - SHARED ENFORCEMENT LEAD
2U-N 2U-R 2U-R DAY ZERO - ENFORCEMENT LEAD IS UNASSIGNED
2Z-N 2Z-R FEDERAL DAY ZERO
DB-N DB-R LEAD CHANGED TO SHARED ENFORCEMENT
DS-N DS-R LEAD CHANGED TO STATE ENFORCEMENT
DY-N DY-R LEAD CHANGED TO FEDERAL ENFORCEMENT
2E-N SV-R SV STATE DAY 0 PLC1, Lead Agency
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 39
-------
SUGGESTED ACTION TYPES FOR AFS REPORTING: REGION 10
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - ADDRESSING ACTIONS
National
OT-N
6B-N
6B-N
7A-N
7E-N
7F-N
8A-N
AG-N
AH-N
2D-N
2D-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
8C-N
9C-N
9C-N
Region State
OT-R OT-R
12-R
X3-R
7A-R
60-R
7F-R
78-R
AG-R
AH-R
LA-R
X2-R
09-R
13-R
2G-R
2R-R
37-R
61 -R
7D-R
93-R
94-R
9F-R
A1-R
A2-R
IN-R
X1-R
X4-R
XI-R
11-R
L2-R
REGIONAL ACTION DESCRIPTION:
OTHER ADDRESSING ACTION
FEDERAL CONSENT AGREEMENT SIGNED
FEDERAL COURT DECREE ISSUED
EPA NOTICE OF NON-COMPLIANCE (SECTION 120)
167 STOP CONSTRUCTION ORDER
1 13D APO COMPLAINT FILED.
COMPLIANCE ORDER 113 FINAL/ISSUED
FEDERAL AIR TOXICS ADMINISTRATIVE ORDER
FEDERAL AIR TOXICS ADMINISTRATIVE PENALTY ORDER
STATE CONSENT AGREEMENT ISSUED
STATE COURT ORDER ISSUED
WA-CIVIL PENALTIES(FORMAL ENFORCE DOC W/PENALTIES)
PSCAA/WA -ASSURANCE OF DISCONTINUANCE
WA/CRO - NOTICE OF PENALTY
SCAPCA/WA-NOTICE & ORDER OF ASSESSMENT
AK - COMPLIANCE ORDERS BY CONSENT (COBC)
IDAHO - CONSENT ORDER ISSUED
ALASKA-SETTLEMENT AGREEMENT
MUTUAL AGREEMENT & ORDER (MAO)
OREGON DEPARTMENT ORDER
ORCAA-NOTICE OF CIVIL PENALTY ASSESSMENT
ALASKA - NUISANCE ABATEMENT ORDER
ALASKA - EMERGENCY ORDER
WDOE/ERO ISSUANCE OF NOTICE OF PENALTY ACTION
STATE ORDER ISSUED
ID-NOV W/PENALTY-RESOLVES W/O CONCENT ORDER OR CIV
1 13(A)(1)SIP ORDER ISSUED BY STATE
PSCAA/WA-INJUNCTIVE RELIEF
CIVIL ACTION BY STATE
Additional Requirements
PAM1 (Total Assessed)
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1 (Total Assessed)
PAM1
PAM1
Additional Requirements
HIGH PRIORITY VIOLATOR (HPV) ACTION LINKING - HPV RESOLVED
National Region State REGIONAL ACTION DESCRIPTION:
VR-N VR-R VR-R VIOLATION RESOLVED
7G-N 7G-R EPA-HPV RESOLVED-RET TO COMPL W/NO ENFORCEMENT ACT
2K-N 2K-R STATE-SRC RETRND TO COMPLIANCE W/NO FURTHER ACTN
TITLE V SELF CERTIFICATIONS AND COMPLIANCE STATUSINote: contains new CMS requirements.)
National Region State REGIONAL ACTION DESCRIPTION:
CC-N C1-R C1-R TITLE V ANNUAL CERT DUE/RECEIVED BY EPA
CC-N T4-R T4-R TITLE 71 ANNUAL COMPL CERT DUE/RECVD - TRIBAL
ER-N 41-R T-V ANNUAL COMPLIANCE CERT REVIEWED BY EPA
ER-N
CB-N
SR-N
T5-R
DA-R
SR-R
TITLE 71 ANNUAL COMPL CERT REVIEWED - TRIBAL
TV ANN COMPL CERT DUE/RCVD BY PERMIT AUTHORITY
TV ANNUAL COMPL. CERT REVIEW BY PERMIT AUTHORITY
Additional Reguirements
DTS1=Due Date. DTA1=Received Date.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in Violation,MC-in Compliance,MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
Results Code:MV-in Violation,MC-in Compliance,MU-Unknown
RDE8=Deviation,Y-Yes or N-No.
DTS1=Due Date. DTA1=Received Date.
Results Code:MV-in violation, MC-in Compliance, MU-
Unknown
An "*" (in the National Column) indicates that the Action Type is an Enforcement Sensitive Action
APPENDIX 3A -PAGE 40
-------
Appendix 3b
AFS National Action Types Applicable
for Tribal Activity
-------
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-------
4/11/2006
AFS NATIONAL ACTION TYPES FOR USE IN DOCUMENTING TRIBAL ACTIVITY
Activity completed at a source located within a tribal authority by tribal inspectors with federal
credentials (without the use of federal resources) or by tribal inspectors with delegated CAA
program authority should be reported to AFS using the following national action types:
NATL
ACT
TYPE
SHORT DESCRIPTION LONG DESCRIPTION
Full Compliance Evaluations (FCEs)
Tl TRIBALFCEON
T2 TRIBAL FCE OFF
TRIBAL ONSITE FCE
TRIBAL OFF SITE FCE
Partial Compliance Evaluations (PCEs)
T3 TRIBAL PCE ON
T4 TRIBAL PCE OFF
T5 TRIBAL PCE COMP
T6 TRIBAL PCE OBS
T7 TRIBAL PCE PER
T8 TRIBAL PCE PRO
TRIBAL ONSITE PCE
TRIBAL OFF SITE PCE
TRIBAL ONSITE COMPLAINT PCE
TRIBAL ONSITE OBSERVATION PCE
TRIBAL ONSITE PERMIT PCE
TRIBAL OFFSITE PROCESS PCE
Investigations
TA TRIBAL INV STAR
TB
Stack Tests
TC
TD
TF
TRIBAL INV COND
TRIBAL STACK
TRIBAL STACK NO
TRIBAL STACK OR
TRIBAL INVESTIGATION
STARTED/INITIATED
TRIBAL INVESTIGATION
CONDUCTED/CONCLUDED
TRIBAL SOURCE TEST CONDUCTED
TRIBAL AUTHORITY REQUIRED
(OWNER/OPERATOR CONDUCTED)
TEST NOT OBSERVED BUT
REVIEWED
TRIBAL UTHORITY REQUIRED
(OWNER/OPERATOR CONDUCTED)
K TEST OBSERVED AND REVIEWED
Title V Annual Compliance Certifications (TV ANN CERTs)
TG TRIBAL TV RECD TV ANN COMPL CERT DUE/RECEIVED BY
TRIBAL AUTHORITY
TH TRIBAL TV REVD TV ANN COMPL CERT REVIEWED BY
TRIBAL AUTHORITY
MACT Non-Applicability
TM TRIBAL MACT NA
TRIBAL MACT FCE/PCE NON-
APPLICABILITY DETERMINATION
-------
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-------
Appendix 3c
AFS National Action Types Allowable
as Duplicate Actions
-------
This Page Intentionally Left Blank
-------
AFS National Action Types Allowable as Duplicates
Normally, action records are reported to AFS with unique action types and dates. There
are a few instances were actions happening on the same day are allowable.
The following National Action Types are allowed to be reported to AFS multiple times
with the same date achieved:
2A EPA SOURCE TEST CONDUCTED
3 A OWNER/OPERATOR - CONDUCTED SOURCE TEST
6 A EPA NO VIS SUED
6C ST SOURCE TEST CONDUCTED
7C STATE NOV ISSUED
8 A EPA 113 (A) ORDER IS SUED
8C STATE ADMINISTRATIVE ORDER IS SUED
CB TV ANNUAL COMPLIANCE CERT DUE/RECVD BY STATE/LOCAL
CC TITLE V COMPLIANCE CERT DUE/RECEIVED BY EPA
ER TITLE V COMPLIANCE CERTIFICATION REVIEW BY EPA
ES EPA CONDUCTED PCE/ ON-SITE
EX EPA PCE/OFF-SITE
PS STATE PCE / ON-SITE
PX STATE PCE / OFF-SITE
SR TITLE V COMPLIANCE CERTIFICATION REVIEW BY STATE TE EPA
REQ (O/O COND) STACK TEST/NOT OBSV BUT REVWD
TO EPA REQ(O/O COND) STACK TEST/OBSERVED & REVIEWED
TR STATE REQ (O/O COND) STACK TEST/NOT OB SV BUT REVWD
TS STATE RECEIPT OF STACK TEST REPORT
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-------
Appendix 4
Listing of Local Control Table Values
for AFS
-------
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-------
LOCAL CONTROL REGION CODES
Mar-09
STFIP LCON DESCRIPTION
01 00 STATE JURISDICTION
01 01 JEFFERSON COUNTY
01 02 HUNTSVILLE
02 A1 METLAKATLA TRIBE
02 US EPA JURISDICTION
02 00 STATE JURISDICTION
04 A1 Ak-Chin Community Council (Maricopa Reservation)
04 A2 Yavapai-Prescott Reservation (Yavapai-Prescott
Board of Directors)
04 A3 Oljatoh Reservation (western Navajo Agency)
04 00 ARIZONA DEPT OF ENVIRONMENTAL QUALITY (GRANTEE)
04 01 MARICOPA COUNTY AIR POLLUTION CONTROL AGENCY
(GRANTEE)
04 02 PIMA COUNTY AIR POLLUTION CONTROL DISTRICT
(GRANTEE)
04 03 PINAL COUNTY AIR POLLUTION CONTROL DISTRICT
(NON-GRANTEE)
04 11 Ak-Chin Community Council (Maricopa Reservation)
04 12 Beclabito Reservation (Shiprock Agency)
04 13 Blue Gap Reservation (Chinle Agency)
04 14 Blue Springs Reservation (Western Navajo Agency)
04 15 Broadway Reservation (Western Navajo Agency)
04 16 Cameron Reservation (Western Navajo Agency)
04 17 Camp Verde (Truxton Cannon Agency)
04 18 Chilchinbeto Reservation (Western Navajo Agency)
04 19 Chinle Reservation (Chinle Agency)
04 20 Coalmine Reservation (Western Navajo Agency)
04 21 Cocopah Reservation (Cocopah Tribal Council)
04 22 Colorado Indian Tribes Council (GRIT Tribal
Council)
04 23 Copper Mine Reservation (Western Navajo Agency)
04 24 Cornfields Reservation (Fort Defiance Agency)
04 25 Coyote Canyon Reservation (Fort Defiance Agency)
04 26 Crystal Reservation (Fort Defiance Agency)
04 27 Denehosto Reservation (Western Navajo Agency)
04 28 Dilkon Community (Western Navajo Agency)
04 29 Forest Lake Reservation (Chinle Agency)
04 30 Fort Apache Reservation
04 31 Fort Defiance Reservation (Fort Defiance Agency)
04 32 Fort McDowell
04 33 Fort Mojave Reservation (Colorado River Agency)
04 34 Fort Yuma Reservation (Fort Yuma Agency)
04 35 Fort Yuma Reservation (Quechan Tribal Council)
04 36 Ganado Reservation (Fort Defiance Agency)
04 37 Gila Bend Reservation
04 38 Gila River Indian Community Council
04 39 Gila River reservation
04 40 Greasewood Reservation (Fort Defiance Agency)
04 41 Havasupai
TRIBAL STABBR
N
N
N
Y
N
N
Y
Y
Y
N
N
N
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
AL
AL
AL
AK
AK
AK
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
APPENDIX 4
PAGE1 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
04 42 Hopi Y AZ
04 43 Houck Reservation (Fort Defiance Agency) Y AZ
04 44 Hulapai Y AZ
04 45 Inscription House Reservation (Western Navajo Y AZ
Agency)
04 46 ITCA Y AZ
04 47 Jeddito Reservation (Fort Defiance Agency) Y AZ
04 48 Kaibito Reservation (Western Navajo Agency) Y AZ
04 49 Kaibob Reservation (Kaibob Paiute Tribal Council) Y AZ
04 50 Kayenta Reservation (Western Navajo Agency) Y AZ
04 51 Kinlichee Reservation (Fort Defiance Agency) Y AZ
04 52 Klagetoh Reservation (Fort Defiance Agency) Y AZ
04 53 Las Vegas Paiute Tribe Y AZ
04 54 Lechee reservation (Western Navajo Agency) Y AZ
04 55 Leupp Reservation (Western Navajo Agency) Y AZ
04 56 Low Mountain Reservation (Fort Defiance Agency) Y AZ
04 57 Lukachukai Reservation (Chinline Agency) Y AZ
04 58 Lupton Reservation (Fort Defiance Agency) Y AZ
04 59 Many Farms Reservation (Chinline Agency) Y AZ
04 60 Mexican Springs Reservation (Fort Defiance Y AZ
Agency)
04 61 Mexican Waters Reservation (Shiprock Agency) Y AZ
04 62 Moapa Y AZ
04 63 Naschitti Reservation (Western Navajo Agency) Y AZ
04 64 Navajo Mountain Reservation (Western Navajo Y AZ
Agency)
04 65 Navajo Nation Y AZ
04 66 Nazlini Reservation (Chinline Agency) Y AZ
04 67 Oak Springs Reservation (Fort Defiance Agency) Y AZ
04 68 Pascua-Yaqui Indian Community (Pascua-Yacqui Y AZ
Tribal Council)
04 69 Pinon Reservation (Chinle Agency) Y AZ
04 70 Quechan Tribe Y AZ
04 71 Red Lake Reservation (Fort Defiance Agency) Y AZ
04 72 Red Lake Reservation (Western Navajo Agency)) Y AZ
04 73 Red Mesa Reservation (Shiprock Agency) Y AZ
04 74 Red Rock Reservation (Shiprock Agency) Y AZ
04 75 Rough Rock Reservation (Chinle Agency) Y AZ
04 76 Round Rock Reservation (Chinline Agency) Y AZ
04 77 Salt River Reservation (Salt River Pima-Maricopa Y AZ
Indian Community)
04 78 San Carlos Apache Reservation (San Carlos Tribal Y AZ
Council)
04 79 San Juan Southern Paiute Council (Southern Paiute Y AZ
Field Station)
04 80 San Xavier Reservation (Papago Agency) Y AZ
04 81 Sanotsee Reservation (Shiprock Agency) Y AZ
04 82 Sawmill Reservation (Fort Defiance Agency) Y AZ
04 83 Shonto Reservation (Western Navajo Agency) Y AZ
04 84 St. Michaels Reservation (Fort Defiance Agency) Y AZ
04 85 Steamboat Reservation (Fort Defiance Agency) Y AZ
APPENDIX 4 PAGE 2 OF 12
-------
STFIP
04
04
04
04
04
04
04
04
04
04
04
04
04
04
05
05
05
05
05
05
05
05
05
05
05
05
05
05
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
LCON
86
87
88
89
90
91
92
93
94
95
96
97
98
99
00
01
02
03
04
05
06
07
08
09
10
11
12
13
AO
A1
A2
A3
A4
A5
A6
A7
A8
A9
BO
B1
B2
B3
B4
B5
B6
B7
B8
B9
CO
DESCRIPTION
Teecnospos Reservation (Shiprock Agency)
Teesto Reservation (Fort Defiance Agency)
Tohono O'odham (Sells Reservation )(Tohono
O'odham Council)
Tolani Lake Reservation (Western Navajo Agency)
Tonto Apache Reservation (Tonto Apache Tribal
Council)
Tsalie-Wheatfields Reservation (Chinle Agency)
Tselani Reservation (Chinline Agency)
Tuba City Reservation (Western Navajo Agency)
Twin Lakes Reservation (Fort Defiance Agency)
White Cone Reservation (Fort Defiance Agency)
White Mountain Apache Tribal Council
Wide Ruins Reservation (Fort Defiance Agency)
NAVAJO NATION
EPA REGION 9'S SPECIAL JURISDICTION
STATE JURISDICTION
DISTRICT 1
DISTRICT 2
DISTRICT 3
DISTRICT 4
DISTRICT 5
DISTRICTS
DISTRICT 7
DISTRICT 8
DISTRICT 9
DISTRICT 10
DISTRICT 11
DISTRICT 12
DISTRICT 13
Mooretown
Lone Pine
Los Cayotes
Lower Lake
Lytton
Manchester/Pt. Arena Porno Indians
Manzanita
Mechoopda (Chico)
Mesa Grande
Middletown
Pinoleville
Morongo
NAEPC
North Fork
OVIWC
Pala
Paskenta
Pauma
Pechanga
Picayune
Robinson
TRIBAL
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
STABBR
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AR
AR
AR
AR
AR
AR
AR
AR
AR
AR
AR
AR
AR
AR
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
APPENDIX 4
PAGE 3 OF 12
-------
STFIP
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
LCON
C1
C2
C3
C4
C5
C6
C7
C8
C9
DO
D1
D2
D3
D4
D5
D6
D7
D8
D9
EO
E1
E2
E3
E4
E5
E6
E7
E8
E9
FO
F1
F2
F3
F4
F5
F6
F7
F8
F9
G1
00
01
02
03
04
05
DESCRIPTION
Pit River
Potter Valley
Quartz Valley
Quechan
Ramona
Redding
Redwood Valley
Resighini
Rincon
Sherwood Valley
Round Valley (Covelo)
Rumsey
San Manuel
San Pasqual
Santa Rosa Rancheria
Santa Rosa Reservation
Santa Ynez
Santa Ysabel
Scotts Valley
Trinidad
Shingle Springs
Smith River
Soboboa
Stewarts Point/Kashia Band
Susanville
Sycuan
Table Mountain
Timbi-sha
Torres Martinez
Laytonville Rancheria
Tule River
Tuolumne
Twenty Nine Palms
Upper Lake/Habematolel
Viejas (Capitan Grande)
Wiyot
Yurok
Chico Rancheria
Colusa Rancheria
Table Bluff Rancheria
CA AIR RESOURCES BOARD (NO REPORTABLE SOURCES)
(GRANTEE)
BAY AREA AIR QUALITY MANAGEMENT DISTRICTURCES)
(GRANTEE)
IMPERIAL COUNTY AIR POLLUTION CONTROL DISTRICT
(NON-GRANTEE)
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTIONSTRICT
(GRANTEE)
VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT
(GRANTEE)
PLACER COUNTY AIR POLLUTION CONTROL DISTRICT
TRIBAL
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
STABBR
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
APPENDIX 4
PAGE 4 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
(NON-GRANTEE)
06 06 AMADOR COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 07 BUTTE COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 08 CALAVERAS COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 09 COLUSA COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 10 EL DORADO COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 11 FEATHER RIVER AIR QUALITY MANAGEMENT DISTRICT N CA
(NON-GRANTEE)
06 12 GLENN COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 13 GREAT BASIN UNIFIED AIR POLLUTION CONTROL N CA
DISTRICT (NON-GRANTEE)
06 14 KERN COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 15 LAKE COUNTY AIR QUALITY MANAGEMENT DISTRICT N CA
(NON-GRANTEE)
06 16 LASSEN COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 17 MOJAVE DESERT AIR QUALITY MANAGEMENT DISTRICT N CA
(NON-GRANTEE)
06 18 MONTEREY BAY UNIFIED AIR POLLUTION CONTROL N CA
DISTRICT (GRANTEE)
06 19 NORTH COAST UNIFIED AIR QUALTY MANAGEMENT N CA
DISTRICT (NON-GRANTEE)
06 20 NORTHERN SIERRA AIR QUALITY MANAGEMENT DISTRICT N CA
(NON-GRANTEE)
06 21 NORTHERN SONOMA AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 22 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT N CA
DISTRICT (GRANTEE)
06 23 SAN DIEGO COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(GRANTEE)
06 24 SAN LUIS OBISPO COUNTY AIR POLLUTION CONTROL N CA
DISTRICT (NON-GRANTEE)
06 25 MARIPOSA COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 26 MENDOCINO COUNTY AIR QUALITY MANAGEMENT DISTRICT N CA
(NON-GRANTEE)
06 27 MODOC COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
06 28 SANTA BARBARA COUNTY AIR POLLUTION CONTROL N CA
DISTRICT (GRANTEE)
06 29 SHASTA COUNTY AIR QUALITY MANAGEMENT DISTRICT N CA
(NON-GRANTEE)
06 30 SISKIYOU COUNTY AIR POLLUTION CONTROL DISTRICT N CA
(NON-GRANTEE)
APPENDIX 4 PAGE 5 OF 12
-------
STFIP
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
LCON
31
32
33
34
35
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
DESCRIPTION
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
(GRANTEE)
TEHAMA COUNTY AIR POLLUTION CONTROL DISTRICT
(NON-GRANTEE)
TUOLUMNE COUNTY AIR POLLUTION CONTROL DISTRICT
(NON-GRANTEE)
YOLO SOLANO AIR QUALITY MANAGEMENT DISTRICT
(NON-GRANTEE)
ANTELOPE VALLEY AIR QUALITY MANAGEMENT DISTRICT
(NON-GRANTEE)
Agua Caliente
Agustine
Alturas Rancheria
Auburn
Barona
Bear River
Benton/UtuUtu Gwaitu
Berry Creek
Big Lagoon
Big Pine
Big Sandy
Big Valley
Bishop Paiute Tribe
Blue Lake
Bridgeport
Buena Vista
Buena Vista
CA Valley Miwok (Sheep Ranch)
Cabazon
Cachil Dehe Band (Colusa)
Cahto (Laytonville)
Cahuilla
Campo Band of Kameyaay Indians
Cedarville Rancheria
Chemehuevi
Chicken Ranch
Cloverdale
Cocopah
Cold Springs
Cortina
Coyote Valley
GRIT
Cuyapaipe
Dry Creek
Duckwater
Elem
Elk Valley
Ely
Enterprise
Fort Bidwell
Fort Independence
TRIBAL STABBR
N CA
N
N
N
N
CA
CA
CA
CA
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
APPENDIX 4
PAGE 6 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
06 81 FortMojave Y CA
06 83 Goshute Y CA
06 84 Graton Y CA
06 85 Greenville Y CA
06 86 Grindstone Y CA
06 87 Guidville Y CA
06 88 Hoopa Y CA
06 89 Hopland Y CA
06 90 Inaja Y CA
06 91 lone Y CA
06 92 ITCC Y CA
06 93 Jackson Y CA
06 94 Jamul Y CA
06 95 Karuk Y CA
06 96 LaJolla Y CA
06 97 LaPosta Y CA
06 99 EPA REGION 9'S SPECIAL JURISDICTION N CA
08 00 STATE JURISDICTION N CO
08 92 SOUTHERN UTE INDIAN TRIBE Y CO
08 98 UTE MOUNTAIN UTE TRIBE Y CO
09 00 STATE JURISDICTION N CT
10 00 STATE JURISDICTION N DE
11 00 STATE JURISDICTION N DC
12 00 STATE JURISDICTION N FL
13 00 STATE JURISDICTION N GA
15 00 HAWAII DEPT OF HEALTH, CLEAN AIR BRANCH (GRANTEE) N HI
15 99 EPA REGION 9'S SPECIAL JURISDICTION N HI
16 BO IDEQ-BOISE REGIONAL OFFICE N ID
16 CO IDEQ - COUER DE'ALENE REGIONAL OFFICE N ID
16 IF IDEQ-IDAHO FALLS REGIONAL OFFICE N ID
16 11 IDEQ-COEUR D'ALENE REGIONAL OFFICE N ID
16 12 KOOTENAI TRIBE OF IDAHO Y ID
16 13 NEZ PERCE TRIBE OF IDAHO Y ID
16 14 SHOSHONE BANNOCK TRIBES Y ID
16 LO IDEQ-LEWISTON REGIONAL OFFICE N ID
16 OS IDEQ-OUT OF STATE PORTABLE FACILITY N ID
16 PO IDEQ-POCATELLO REGIONAL OFFICE N ID
16 TF IDEQ-TWIN FALLS REGIONAL OFFICE N ID
16 UK IDEQ-PORTABLE FACILITY WHEN LOCATION IS UNKNOWN N ID
16 US EPA JURISDICTION N ID
16 00 STATE JURISDICTION N ID
17 00 STATE JURISDICTION N IL
18 00 STATE JURISDICTION N IN
19 00 STATE JURISDICTION N IA
19 01 POLK COUNTY N IA
19 02 LINN COUNTY N IA
20 00 STATE JURISDICTION N KS
21 00 STATE JURISDICTION N KY
21 01 JEFFERSON COUNTY N KY
22 00 STATE JURISDICTION N LA
23 CM CENTRAL MAINE REGION N ME
APPENDIX 4 PAGE 7 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
23 EM EASTERN MAINE REGION N ME
23 SM SOUTHERN MAINE REGION N ME
23 00 STATE JURISDICTION N ME
24 00 STATE JURISDICTION N MD
25 00 STATE JURISDICTION N MA
25 01 MA WESTERN REGION N MA
25 02 MA CENTRAL REGION N MA
25 03 MA NORTHEAST REGION N MA
25 04 MA SOUTHEAST REGION N MA
26 00 STATE JURISDICTION N Ml
26 01 BAY MILLS INDIAN COMMUNITY Y Ml
26 02 CHIPPEWA-OTTAWA RESOURCE AUTHORITY Y Ml
26 03 GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA Y Ml
26 04 HANNAHVILLE INDIAN COMMUNITY Y Ml
26 05 INTER-TRIBAL COUNCIL OF MICHIGAN Y Ml
26 06 KEWEENAW BAY INDIAN COMMUNITY Y Ml
26 07 LAC VIEUX DESERT BAND OF CHIPPEWA Y Ml
26 08 LITTLE RIVER BAND OF OTTAWA Y Ml
26 09 LITTLE TRAVERSE BAY BANDS OF ODAWA Y Ml
26 10 MATCH-E-BE-NASH-SHE-WISH BAND OF POTTAWATOMI Y Ml
26 11 NOTTAWASEPPI HURON POTAWATOMI Y Ml
26 12 POKAGON BAND OF POTAWATOMI Y Ml
26 13 SAGINAW CHIPPEWA INDIAN TRIBE Y Ml
26 14 SAULT STE. MARIE TRIBE OF CHIPPEWA Y Ml
27 00 STATE JURISDICTION N MN
27 01 BOIS FORTE BAND OF CHIPPEWA Y MN
27 02 FOND DU LAC BAND OF CHIPPEWA Y MN
27 03 GRAND PORTAGE BAND OF CHIPPEWA Y MN
27 04 LEECH LAKE TRIBE OF OJIBWE Y MN
27 05 LOWER/UPPER SIOUX COMMUNITIES Y MN
27 06 MILLE LACS BAND OF OBJIBWE Y MN
27 07 MINNESOTA CHIPPEWA TRIBE Y MN
27 08 PRAIRE ISLAND INDIAN COMMUNITY Y MN
27 09 RED LAKE BAND OF CHIPPEWA Y MN
27 10 SHAKOPEE MDEWAKANTON SIOUX COMMUNITY Y MN
27 11 WHITE EARTH BAND OF CHIPPEWA Y MN
28 00 STATE JURISDICTION N MS
29 00 STATE JURISDICTION N MO
30 00 STATE JURISDICTION N MT
30 74 BLACKFEET TRIBE Y MT
30 76 CHIPPEWA CREE TRIBE Y MT
30 77 CONFEDERATED SALISH & KOOTENAI TRIBES Y MT
30 78 CROW TRIBE Y MT
30 82 GROSVENTRE&ASSINIBOINE TRIBES Y MT
30 84 NORTHERN CHEYENNE TRIBE Y MT
31 01 STATE JURISDICTION N NE
31 02 LINCOLN - LANCASTER COUNTY N NE
31 03 CITY OF OMAHA N NE
32 00 NEVADA DIVISION OF ENVIRONMENTAL PROTECTION N NV
(GRANTEE)
32 01 CLARK COUNTY HEALTH DISTRICT AIR POLLUTION N NV
APPENDIX 4 PAGE 8 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
CONTROL (GRANTEE)
32 02 WASHOE COUNTY DISTRICT HEALTH DEPARTMENTON N NV
(GRANTEE)
32 11 Battle Mountain Y NV
32 12 Carson Indian Colony Y NV
32 13 Dresslerville Indian Colony Y NV
32 14 Duck Valley Y NV
32 15 Elko Indian Colony Y NV
32 16 Ely Indian Colony Y NV
32 17 Fallen Reservation & Colony (Fallen Business Y NV
Council)
32 18 Fort McDermitt Reservation (Fort McDermitt Tribal Y NV
Council)
32 19 ITCN Y NV
32 20 Las Vegas Indian Colony (Las Vegas Colony Y NV
Council) Las Vegas Paiute Tribe
32 21 Lovelock Indian Colony (Lovelock Tribal Council) Y NV
32 22 Moapa River Indian Reservation (Moapa Business Y NV
Council)
32 23 Pyramid Lake Reservation (Pyramid Lake Paiute Y NV
Tribal Council) Pyramid Lake
32 24 Reno-Sparks Indian Colony (Reno-Sparks Tribal Y NV
Council) Reno/Sparks Indian C
32 25 Ruby Valley (Te-moak) Reservation (Tribal Council Y NV
of the Te-Moak Western Sh
32 26 Shoshone-Paiute Tribes Y NV
32 27 South Fork Indian Colony (South Fork Band Y NV
Council)
32 28 Stewart Indian Colony (Stewart Indian Community Y NV
Council)
32 29 Summit Lake Reservation (Summit Lake Paiute Y NV
Council)
32 30 Walker River Reservation (Walker River Paiute Y NV
Tribal Council)
32 31 Washoe Tribal Council Y NV
32 32 Wells Indian Colony Y NV
32 33 Winnemucca Indian Colony Y NV
32 34 Yerington Paiute Tribal Council Y NV
32 35 Yomba Y NV
32 99 EPA REGION 9'S SPECIAL JURISDICTION N NV
33 00 STATE JURISDICTION N NH
34 00 STATE JURISDICTION N NJ
35 00 STATE JURISDICTION N NM
35 01 CITY OF ALBUQUERQUE N NM
35 98 NAVAJO NATION Y NM
35 99 EPA JURISDICTION N NM
36 ON ONEIDA NATION Y NY
36 SN SENECA NATION Y NY
36 00 STATE JURISDICTION N NY
37 00 STATE JURISDICTION N NC
37 01 ARO-ASHEVILLE REGIONAL OFFICE N NC
APPENDIX 4 PAGE 9 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
37 03 MRO-MOORESVILLE REGIONAL OFFICE N NC
37 04 WSRO-WINSTON SALEM REGIONAL OFFICE N NC
37 05 RRO-RALEIGH REGIONAL OFFICE N NC
37 06 FRO-FAYETTEVILLE REGIONAL OFFICE N NC
37 07 WARO-WASHINGTON REGIONAL OFFICE N NC
37 08 WIRO-WILMINGTON REGIONAL OFFICE N NC
37 09 BUNCOMBE COUNTY N NC
37 10 FORSYTH COUNTY N NC
37 11 MECKLENBURG COUNTY N NC
37 12 EPA JURISDICTION N NC
38 00 STATE JURISDICTION N ND
38 93 SPIRIT LAKE TRIBE Y ND
38 94 STANDIND ROCK SIOUX TRIBE Y ND
38 95 THREE AFFILIATED TRIBES Y ND
38 96 TURTLE MOUNTAIN BAND OF CHIPPEWAS Y ND
39 00 STATE JURISDICTION N OH
40 00 STATE JURISDICTION N OK
41 ER ODEQ - EASTERN REGIONAL OFFICE N OR
41 NW ODEQ - NORTHWEST REGIONAL OFFICE N OR
41 R1 BURNS PAIUTE Y OR
41 R2 COOS, LOWER UMPQUA & SIUSLAW Y OR
41 R3 COQUILLE INDIAN TRIBE Y OR
41 R4 COW CREEK BAND OF UMPQUA TRIBES OF INDIANS Y OR
41 R5 CONFEDERATED TRIBES OF GRAND RONDE Y OR
41 R6 KLAMATH INDIAN TRIBE Y OR
41 R7 SILETZ CONFEDERATED TRIBES Y OR
41 R8 CONFEDERATED TRIBES OF UMATILLA Y OR
41 R9 CONFEDERATED TRIBES OF WARM SPRINGS Y OR
41 US EPA JURISDICTION N OR
41 WR ODEQ - WESTERN REGIONAL OFFICE N OR
41 00 STATE JURISDICTION N OR
41 08 LANE REGIONAL AIR POLLUTION AUTHORITY N OR
42 00 STATE JURISDICTION N PA
42 01 ALLEGHENY COUNTY HEALTH DEPARTMENT N PA
42 02 PHILADELPHIA AIR MANAGEMENT SERVICES N PA
44 00 STATE JURISDICTION N Rl
45 00 STATE JURISDICTION N SC
46 00 STATE JURISDICTION N SD
46 73 ASSINBOINE& SIOUX TRIBES Y SD
46 75 CHEYENNE RIVER SIOUX TRIBE Y SD
46 79 CROW CREEK SIOUX TRIBE Y SD
46 81 FLANDREAU SANTEE SIOUX TRIBE Y SD
46 83 LOWER BRULE SIOUX TRIBE Y SD
46 87 OGLALA SIOUX TRIBE Y SD
46 89 ROSEBUD SIOUX TRIBE Y SD
46 90 SISSETON-WAHPETON OYATE Y SD
46 99 YANKTON SIOUX TRIBE Y SD
47 00 STATE JURISDICTION N TN
47 01 NASHVILLE-DAVIDSON COUNTY N TN
47 02 MEMPHIS-SHELBY COUNTY N TN
47 03 CHATTANOOGA-HAMILTON COUNTY N TN
APPENDIX 4 PAGE 10 OF 12
-------
STFIP
47
48
48
48
48
48
48
48
48
48
48
48
48
48
48
48
48
48
49
49
49
49
49
49
50
51
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
LCON
04
00
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
00
86
88
91
97
98
00
00
US
00
01
02
03
04
05
06
07
09
10
11
12
13
14
30
31
32
33
34
35
36
37
38
39
DESCRIPTION
KNOX COUNTY
STATE JURISDICTION
REGION 1, AMARILLO
REGION 2, LUBBOCK
REGION 3, ABILENE
REGION 4, DALLAS/FT WORTH
REGION 5, TYLER
REGION 6, EL PASO
REGION 7, MIDLAND
REGION 8, SAN ANGELO
REGION 9, WACO
REGION 10, BEAUMONT
REGION 11, AUSTIN
REGION 12, HOUSTON
REGION 13, SAN ANTONIO
REGION 14, CORPUS CHRISTI
REGION 15, HARLINGEN
REGION 16, LAREDO
STATE JURISDICTION
NORTHWESTERN BAND OF SHOSHONI NATION
PAIUTE INDIAN TRIBE OF UTAH
SKULL VALLEY BAND OF GOSHUTE INDIANS
UTE INDIAN TRIBE
NAVAJO NATION
STATE JURISDICTION
STATE JURISDICTION
EPA JURISDICTION
STATE JURISDICTION
PUGET SOUND CLEAN AIR AGENCY
OLYMPIC REGIONAL CLEAN AIR AGENCY
NORTHWEST CLEAN AIR AGENCY
SOUTHWEST CLEAN AIR AUTHORITY
YAKIMA REGIONAL CLEAN AIR AUTHORITY
BENTON CLEAN AIR AUTHORITY
SPOKANE COUNTY AIR POLLUTION CONTROL AUTHORITY
DEPT OF ECOLOGY - CENTRAL REGIONAL OFFICE (CRO)
DEPT OF ECOLOGY - INDUSTRIAL SECTION
DEPT OF ECOLOGY - SOUTHWEST REGIONAL OFFICE (SRO)
DEPT OF ECOLOGY - NUCLEAR WASTE SECTION
DEPT OF ECOLOGY - NORTHWEST REGIONAL OFFICE (NRO)
DEPT OF ECOLOGY - EASTERN REGIONAL OFFICE (ERO)
CONFEDERATED TRIBES OF CHEHALIS
CONFEDERATED TRIBES OF COLVILLE
COWLITZ INDIAN TRIBE
HOH INDIAN TRIBE
JAMESTOWN S'KLALLAM TRIBE
KALISPEL TRIBE OF INDIANS
LOWER ELWHA TRIBAL COUNCIL
LUMMI INDIAN NATION
MAKAH INDIAN TRIBE
MUCKLESHOOT INDIAN TRIBE
TRIBAL
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
Y
Y
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
STABBR
TN
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
UT
UT
UT
UT
UT
UT
VT
VA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
APPENDIX 4
PAGE 11 OF 12
-------
STFIP LCON DESCRIPTION TRIBAL STABBR
53 40 NISQUALLY INDIAN TRIBE Y WA
53 41 NOOKSACK INDIAN TRIBE Y WA
53 42 PORT GAMBLE S'KLALLAM TRIBE Y WA
53 43 PUYALLUP TRIBE OF INDIANS Y WA
53 44 QUILEUTE INDIAN TRIBE Y WA
53 45 QUINAULT INDIAN NATION Y WA
53 46 SAMISH INDIAN NATION Y WA
53 47 SAUK-SUIATTLE INDIAN TRIBE Y WA
53 48 SHOAL WATER BAY INDIAN TRIBE Y WA
53 49 SKOKOMISH INDIAN NATION Y WA
53 50 SNOQUALMIE TRIBE Y WA
53 51 SPOKANE TRIBE OF INDIANS Y WA
53 52 SQUAXIN ISLAND TRIBE Y WA
53 53 STILLAGUAMISH TRIBE Y WA
53 54 SUQUAMISH INDIAN TRIBE Y WA
53 55 SWINOMISH INDIAN TRIBE Y WA
53 56 TULALIP TRIBES OF WASHINGTON Y WA
53 57 UPPER SKAGIT INDIAN TRIBE Y WA
53 58 YAKAMA NATION Y WA
54 00 STATE JURISDICTION N WV
55 00 STATE JURISDICTION N Wl
55 01 BAD RIVER BAND OF LAKE SUPERIOR CHIPPEWA Y Wl
55 02 FOREST COUNTY POTAWATOMI COMMUNITY Y Wl
55 03 HO-CHUNK NATION Y Wl
55 04 LAC COURTE OREILLES BAND OF CHIPPEWA Y Wl
55 05 LAC DU FLAMBEAU BAND OF CHIPPEWA Y Wl
55 06 MENOMINEE INDIAN TRIBE OF WISCONSIN Y Wl
55 07 ONEIDA TRIBE OF WISCONSIN Y Wl
55 08 RED CLIFF BAND OF LAKE SUPERIOR CHIPPEWA Y Wl
55 09 ST. CROIX CHIPPEWA TRIBE OF WISCONSIN Y Wl
55 10 SOKAOGON CHIPPEWA COMMUNITY Y Wl
55 11 STOCKBRIDGE-MUNSEE COMMUNITY Y Wl
56 00 STATE JURISDICTION N WY
56 80 EASTERN SHOSHONE TRIBE Y WY
56 85 NORTHERN ARAPAHO TRIBE Y WY
60 00 AMERICAN SAMOA (NO REPORTABLE SOURCES) (NON-GRANTEE) Y AS
60 99 EPA REGION 9'S SPECIAL JURISDICTION N AS
66 00 GUAM EPA (NO SOURCES TO REPORT)_(GRANTEE) N GU
66 99 EPA REGION 9'S SPECIAL JURISDICTION N GU
69 00 MARIANNAS PROTECTORATE-CONFEDERATION OFNORTHERN N MP
MARIANAS ISLANDS-NONGRANTEE
69 99 EPA REGION 9'S SPECIAL JURISDICTION N MP
72 00 STATE JURISDICTION N PR
78 00 STATE JURISDICTION N VI
APPENDIX 4 PAGE 12 OF 12
-------
Appendix 5
Air Subpart Tables for New Source
Performance Standards (NSPS) and
Most Achievable Control Technology
(MACT)
-------
This Page Intentionally Left Blank
-------
NSPS (PART 60) SUBPARTS
Mar-09
SUBP NSPS (PART 60) SUBPARTS
A GENERAL PROVISIONS
AA ELEC-ARC STEEL FURNACE 10/21/74-8/17/83
AA/A EL-ARC FRN, ARGON-O2 DECARB VESSEL AFTER 8/7/83
AAA NEW RESIDENTIAL WOOD HEATERS
AAAA SMALL MUNICIPAL WASTE COMBUST UNITS CONSTR AFTER 19990830
B STATE PLANS FOR DESIGNATED FACILITIES
BB KRAFT PULP MILLS
BBB RUBBER TIRE MANUFACTURE
BBBB EXISTING SMALL MUNICIPAL WASTE COMBUSTION (MWC) UNITS
C EMISSION GUIDELINES AND COMPLIANCE TIMES
C/B LARGE MWC CONSTRUCTED ON OR BEFORE SEPT. 20, 1994
C/C MUNICIPAL SOLID WASTE LANDFILLS
C/D EM GUIDELINES AND COMP TIMES FOR SULFURIC ACID PLANTS
CC GLASS MANUFACTURING PLANT
CCCC COMMERCIAL & INDUSTRIAL SOLID WASTE INCINERATORS CONSTRUCTED
CE EXISTING HOSPITAL/MEDICAL/INFECTIOUS WASTE INCINERATORS
D FOSSIL FUEL GENER BUILT AFTER 8/17/71
DA ELEC UTIL STEAM GENER AFTER 9/18/78
DB INDUS-COMMERC-INSTITUTL STEAM GENERATOR
DC SMALL INDUS-COMMER-INSTITUTL STEAM GENER
DD GRAIN ELEVATORS
ODD VOC EMISS FROM POLYMER MANUFACTURING
DDDD GUIDE/TIMES-COMMER/IND SOLID WASTE INCIN CONSTRUC =>11/30/99
E INCINERATORS
E/B LARGE MWC CONSTR AFTER 19940920
EA MUNICIPAL WASTE COMBUSTORS
EC NEW HOSPITAL/MEDICAL/INFECTIOUS WASTE INCINERATORS
EE SURFAC COATING OF METAL FURNITURE
EEEE OTHER SOLID WASTE INCIN UNITS CONSTR AFTER 20041209
F PORTLAND CEMENT PLANTS
FFF FLEXIBLE VINYL/URETHANE COATING/PRINTING
FFFF OTHER SOLID WASTE INCIN UNITS CONSTR AFTER 20041209
G NITRIC ACID PLANTS
GG STATIONARY GAS TURBINES
GGG EQUIP VOC LEAKS PETROLEUM REFINERIES
GGG/A EQUIP LEAKS OF VOC IN PETROL REFIN CONSTR AFTER 20061107
H SULFURIC ACID PLANTS
HH LIME MANUFACTURING PLANTS
HHH SYNTHETIC FIBER PRODUCTION FACILITIES
HHHH COAL-FIRED ELECTRIC STEAM GENERATING UNITS
I HOT MIX ASPHALT FACILITIES
III VOC EMISS OF SOCMI AIR-O2 UNIT PROCESS
MM DIESEL ENGINES COMPRESSION COMBUSTION ENGINES
J PETROLEUM REFINERIES
J/A PETROLEUM REFINERIES AFTER MAY 14, 2007
JJJ PETROLEUM DRY CLEANERS
JJJJ STATIONARY SPARK IGNITION COMBUSTION ENGINES
APPENDIX 5
PAGE 1
-------
SUBP NSPS (PART 60) SUBPARTS
K PETROLEUM STORAGE VESSEL 6/11/73 5/19/78
KA PETROLEUM STORAGE VESSEL 5/19/73 7/23/84
KB VOLATILE LIQ/PETRO STORAGE VESSEL 7/23/84
KK LEAD-ACID BATTERY MANUFACTURING PLANTS
KKK VOC EMISS, ONSHORE NATURAL GAS PROC PLNT
KKKK STATIONARY COMBUSTION TURBINES
L SECONDARY LEAD SMELTERS
LL METALLIC MINERAL PROCESSING PLANTS
LLL SO2 EMISS, ONSHORE NATURAL GAS PROC PLNT
M SECONDARY BRASS & BRONZE PRODUCTN PLANTS
MM AUTO/LT-DUTY TRK SURFACE COATING OPERATN
N PRIMARY EMISS BASIC O2 PROCESS FURNACES
NA SECNDRY EMISS BASIC O2-PROC STEEL FACIL
NN PHOSPHATE ROCK PLANTS
NNN VOC EMISS OF SOCMI DISTILLATION OPERATN
O SEWAGE TREATMENT PLANTS
OOO NONMETALLIC MINERAL PROCESSING PLANTS
P PRIMARY COPPER SMELTERS
PP AMMONIUM SULFATE MANUFAC
PPP WOOL FIBERGLASS INSULATION PRODUCTION - NSPS
Q PRIMARY ZINC SMELTERS
QQ GRAPH ART: PUBLICATION ROTOGRAVURE PRINT
QQQ VOC EMISS PETRO REFINERY WATERWASTE SYS
R PRIMARY LEAD SMELTERS
RR PRESSR-SENST TAPE, LABEL SURFACE COATING
RRR SOCMIREACTOR
S PRIMARY ALUMINUM REDUCTION PLANTS
SS LARGE APPLIANCES
SSS MAGNETIC TAPE COATING
T PHOSPHATE FRTLZR: WET-PROC PHOSPH ACID
TT METAL COIL SURFACE COATING
TTT IND-SURF-COAT: PLASTICS, BUSINESS MACHNS
U PHOSPHATE FRTLZR: SUPERPHOSPHORIC ACID
UU ASPHALT PROCESSING & ROOFING MANUFACTURE
UUU CALCINERS/DRYERS IN MINERAL INDUSTRIES
V PHOSPHATE FRTLZR: DIAMMONIUM PHOS PLANT
VV EQUIPT VOC LEAKS IN SYNTH-ORGAN-CHEM MFC
VV/A SOCMI EQUIPMENT LEAKS OF VOC CONSTR AFTER 20061107
VVV POLYMERIC COATING OF SUPPORTING SUBSTRATS FACILITIES - NSPS
W PHOSPHATE FRTLZR: TRIPLE SUPERPHOS PLNT
WW BEVERAGE CAN SURFACE COATING
WWW MUNICIPAL SOLID WASTE LANDFILLS
X PHOSPHATE FRTLZR: GRANULAR 3-SUPER STOR
XX BULK GASOLINE TERMINALS
Y COAL PREPARATION PLANTS
Z FERROALLOY PRODUCTION FACILITIES
APPENDIX 5 PAGE 2
-------
NESHAPS NONMACT (PART 61) SUBPARTS
Mar-09
SUBP NESHAPS NONMACT (PART 61) DESCRIPTION
A GENERAL PROVISIONS
B RADON FROM UNDERGROUND URANIUM MINES
BB BENZENE EMISS FROM BENZENE TRANSFR OPER
C BERYLLIUM
D BERYLLIUM ROCKET MOTOR FIRING
E MERCURY
F VINYL CHLORIDE
FF BENZENE WASTE OPERATIONS
H RADIONUCS OTR THN RADON FROM DPT OF ENGY
I RADIONUCS NRC LICNSD OR FEDRL, NOT SUB-H
J EQUIP LEAK (FUGITIVE EMISS SRC) BENZENE
K RADIONUCS FROM ELEMENTAL PHOSPHORUS PLNT
L BENZENE FROM COKE BY-PRODUCT RECOVERY
M ASBESTOS
N INORGANIC ARSENIC, FROM GLASS MANUFACT
O INORG ARSENIC FROM PRIMARY COPPER SMLTR
P INORG ARSENIC, ARS TRIOXIDE, METAL ARS
Q RADON FROM DOE FACILITIES
R RADON FROM PHOSPHOGYMSUM STACKS
T RADON, DISPOSAL OF URANIUM MILL TAILINGS
V EQUIPMENT LEAKS (FUGITIVE EMISSIONS SRC)
W RADON FROM OPERATING MILL TAILINGS
Y BENZENE EMISS FROM BNZN STORAGE VESSELS
APPENDIX 5 PAGES
-------
NESHAPS MACT (PART 63) SUBPARTS
Mar-09
SUBP NESHAPS MACT (PART 63) DESCRIPTION
A GENERAL PROVISIONS
AA PHOSPERIC ACID MANUFACTURING PLANTS
AAAA MUNICIPAL SOLID WASTE LANDFILLS
AAAAA LIME MANUFACTURING
B REQ FOR CONTROL TECHNOLOGY DETERMINATIONS FOR MAJOR SOURCES
BB PHOSPHATE FERTILIZERS
BBBBB SEMICONDUCTOR MANUFACTURING
C DELISTINGS OF HAPS
CC PETROLEUM REFINERIES
CCC STEEL PICKLING-HCI PROCESS FACILITIES AND HCI REG PLANTS
CCCC MANUFACTURING OF NUTRITIONAL YEAST
CCCCC COKE OVENS: PUSHING, QUENCHING AND BATTERY STACKS
D COMPLIANCE EXTENSION, EARLY HAP REDUCTN
DD OFF-SITE WASTE AND RECOVERY OPERATIONS
ODD MINERAL WOOL PRODUCTION
DDDD PLYWOOD AND COMPOSITE WOOD PRODUCTS
DDDDD INDUSTRIAL/COMMERCIAL/INSTITUTIONAL BOILERS & PROCESS HEATER
E APPROVAL OF STATE PROGRAMS & DELEGATION OF AUTHORITY
EE MAGNETIC TAPE MFG. OPERATIONS
EEE ALL HAZARDOUS WASTE INCINERATORS
EEEE ORGANIC LIQUIDS DISTRIBUTION (NON-GASOLINE)
EEEEE IRON AND STEEL FOUNDRIES
F SYNTHETIC HAZARDOUS ORGANICS (SOCMI) STANDARDS
FFFF MISCELLANEOUS ORGANIC CHEMICAL MANUFACTURING (MON)
FFFFF INTEGRATED IRON AND STEEL MANUFACTURING
G STORAGE OF HAZARDOUS ORGANICS
GG AEROSPACE MFG. & REWORK
GGG PHARMACEUTICAL MANUFACTURING
GGGG SOLVENT VEGETABLE OIL EXTRACTION
GGGGG SITE REMEDIATION
H EQUIPMENT LEAKS OF HAZARDOUS ORGANICS
HH OIL AND NATURAL GAS PRODUCTION FACILITIES
HHH NATURAL GAS TRANSMISSION & STORAGE FACILITIES
HHHH WET FORMED FIBERGLASS MAT PRODUCTION
HHHHH MISCELLANEOUS COATING MANUFACTURING FACILITIES
I NEGOTIATED REGS: EQUIP LEAKS, HAZ-ORGNCS
II SHIPBUILDINGS SHIP REPAIR
III FLEXIBLE POLYURETHANE FOAM PRODUCTION
MM SURFACE COATING OF AUTO AND LIGHT DUTY TRUCKS
Mill MERCURY CELL CHLOR-ALKALI PLANTS
J POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION
JJ WOOD FURNITURE
JJJ GROUP IV POLYMERS AND RESINS
JJJJ NESHAP FOR PAPER & OTHER WEB SURFACE COATINGS
JJJJJ BRICK & STRUCTURAL CLAY PRODUCTS
KK PRINTING & PUBLISHING
KKKK METAL CAN (SURFACE COATING)
APPENDIX 5
PAGE 4
-------
SUBP NESHAPS MACT (PART 63) DESCRIPTION
KKKKK CLAY CERAMICS MANUFACTURING
L COKE OVEN BATTERIES
LL PRIMARY ALUMINUM REDUCTION PLANTS
LLL PORTLAND CEMENT PLANTS
LLLLL ASPHALT PROCESSING AND ASPHALT ROOFING MANUFACTURING
M DRY CLEANERS PERCHLOROETHYLENE
MM PULP MILL CHEMICAL RECOVERY BOILER
MMM PESTICIDE ACTIVE INGREDIENT PRODUCTION
MMMM MISC. METAL PARTS AND PRODUCTS SURFACE COATING OPERATIONS
MMMMM FLEXIBLE POLYURETHANE FOAM FABRICATION OPERATIONS
N CHROMIUM ELECTROPLATING
NNN WOOL FIBERGLASS MANUFACTURING
NNNN SURFACE COATING OF LARGE APPLIANCES
NNNNN HYDROCHLORIC ACID PRODUCTION FUMED SILICA PRODUCTION
O ETHYLENE OXIDE STERILIZERS
OO OFF-SITE WASTE AND RECOVERY OPERATIONS - TANK STANDARDS
OOO MANUFACTURE OF AMINO/PHENOLIC RESINS 40 CFR 63.1419
OOOO PRINTING, COATING AND DYEING OF FABRICS AND OTHER TEXTILES
PP OFF-SITE WASTE AND RECOVERY OPERATIONS - CONTAINER STANDARDS
PPP POLYETHER POLYOLS PRODUCTION - MACT NESHAP
PPPP PLASTIC PARTS (SURFACE COATING)
PPPPP ENGINE TEST CELLS/STANDS
Q INDUSTRIAL PROCESS COOLING TOWERS
QQ OFF-SITE WASTE AND RECOVERY OPERATIONS - SURFACE IMPOUNDMENT
QQQ PRIMARY COPPER
QQQQ SURFACE COATING OF WOOD BUILDING PRODUCTS
QQQQQ FRICTION MATERIALS MANUFACTURING FACILITIES
R GASOLINE DISTRIBUTION
RR OFF-SITE WASTE AND RECOVERY OPERATIONS - INDIVIDUAL DRAIN SY
RRR SECONDARY ALUMINUM PRODUCTION
RRRR SURFACE COATING OF METAL FURNITURE
RRRRR TACONITE IRON ORE PRODUCTION
S PULP AND PAPER
SS NATL EMISS STD- CLOSED VENT SYS/CTRL DEVICES, 40 CFR 63.980
SSSS METAL COIL
SSSSS REFRACTORY PRODUCTS MANUFACTURING
T HALOGENATED SOLVENT CLEANING
TT EQUIPMENT LEAKS - CONTROL LEVEL 1
TTT PRIMARY LEAD SMELTERS
TTTT LEATHER FINISHING OPERATIONS
TTTTT PRIMARY MAGNESIUM
U ELASTOMERS & SYNTHETIC RUBBER PRODUCTION (POLYMERS/RESINS G1
UU NTL EMISS. STD FOR EQUIP LEAKS-CONTROL 2 STD, 40 CFR 63.1019
UUU NESHAP FOR PETROLEUM REFINERIES: CCU'S, CRU'S & SRU'S
UUUU CELLULOSE PRODUCT MANUFACTURING
VV OFF-SITE WASTE & RECOVERY - OIL-WATER & ORGANIC-WATER SEPARA
VVV PUBLICLY OWNED TREATMENT WORKS - MACT NESHAP
VVVV NEW AND EXISTING BOAT MANUFACTURING FACILITIES
W EPOXY RESINS & NON-NYLON POLYAMIDES PRODUCTION
WW NATL EMIS STD - STORAGE VESSELS (TANKS), 40 CFR 63.1060
APPENDIX 5
PAGES
-------
SUBP NESHAPS MACT (PART 63) DESCRIPTION
WWWW REINFORCED PLASTIC COMPOSITES PRODUCTION
WWVWW HOSPITAL ETHYLENE OXIDE STERILIZERS
X SECONDARY LEAD SMELTERS
XX ETHYLENE MPF: HEAT EXCHANGE SYSTEMS & WASTE OPERATIONS
XXX FERROALLOY PRODUCTION
XXXX RUBBER TIRE MANUFACTURING
Y MARINE TANK VESSEL LOADING & UNLOADING OPERATIONS
YY GENERIC MACT STANDARDS
YYYY STATIONARY COMBUSTION TURBINES
YYYYY ELECTRIC ARC FURNACE STEELMAKING AREA SOURCES
ZZZZ RECIPROCATING INTERNAL COMBUSTION ENGINES (RICE)
ZZZZZ IRON AND STEEL FOUNDRIES AREA SOURCES
6B GASOLINE DISTRIBUTION BULK TERMINALS
6C GASOLINE DISPENSING FACILITIES- AREA SOURCES
6D POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION AREA SOURCES
6E PRIMARY COPPER SMELTING AREA SOURCES
6F SECONDARY COPPER SMELTING AREA SOURCES
6G PRIMARY NONFERROUS METALS, ZN, CD AND BE AREA SOURCES
6H PAINT STRIP & MISC SURFACE COATING OPERATIONS AREA SOURCES
6L ACRYLIC AND MODACRYLIC FIBERS PRODUCTION AREA SOURCES
6M CARBON BLACK PRODUCTION AREA SOURCES
6N CHEMICAL MANUFACTURING AREA SOURCES
6O FLEXIBLE POLYURETHANE FOAM PROD & FAB AREA SOURCES
6P LEAD ACID BATTERY MANUFACTURING AREA SOURCES
6Q WOOD PERSERVING AREA SOURCES
6R CLAY CERAMICS MFC AREA SOURCES
6S GLASS MFC AREA SOURCES
6T SECONDARY NONFERROUS METALS AREA SOURCES
6W PLATING AND POLISHING OPERATIONS
6X NINE METAL FABRICATION AND FINISHING SOURCE CATEGORIES
APPENDIX 5
PAGE 6
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Appendix 6
AFS Security
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, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
1 Office of Enforcement and Compliance Assurance
a Office of Compliance
1200 Pennsylvania Avenue NW
Washington, DC 20460
MEMORANDUM
SUBJECT: Welcome to AFS!
TO: The Newest AFS User
FROM: Akachi Imegwu, AFS Security Manager
We have processed your new user profile and you will now be able to start using the largest (and oldest) air
enforcement and compliance database in the Nation!
This informational material was developed to outline briefly the security measures for the Air Facility System
(AFS), explain why these measures were developed, and to establish the requirement for compliance. It also serves
as a reference for useful links to information and contacts. The following topics will be covered in this memo:
I. EPA's Security Measures for AFS
II. AFS Application Guidelines for All Users
III. Guidelines for Handling Enforcement - Sensitive Data
IV. Protecting Your Password
V. Logging in for the First Time
VI. Training Movie on the Web: AFS Rules of Behavior
VII. Summary Remarks
VIII. Useful Links and Contacts
I. EPA's SECURITY MEASURES FOR AFS
The security measures for AFS are intended to protect the air compliance data that State and local agencies
periodically submit to EPA. This protection includes measures to protect against unauthorized modification or loss
of data, while at the same time protecting the underlying computer system that EPA operates.
AFS is an AD ABAS database management system located on EPA's National Computer Center (NCC) mainframe.
As such, AFS follows the security procedures set forth by the NCC which primarily involves the use of User
Accounts, User IDs, passwords and ADABAS/Natural Security. Briefly, these procedures require:
. Any individual wanting to access data in the AFS database must have authorization to use a mainframe
account and obtain an NCC User ID. The ID and a secure password (determined by the User) must be
used when accessing the NCC mainframe and the AFS data base. State and local agency Users are
given limited update authority (i.e., they may only add or modify data for their particular agency).
A User ID is only assigned to an individual (rather than an agency) and only to an individual that is
recommended for access by the State or local agency (in writing) and approved by the appropriate EPA
Regional Office AFS contact and Regional RACF Administrator.
Individuals granted User IDs have a responsibility to use them in an appropriate manner at all times and ensure that
the access they have been personally granted is not shared with others (either deliberately or inadvertently).
II. AFS APPLICATION GUIDELINES FOR ALL USERS
-------
AFS supports EPA, as well as State and local agencies, needing information to carry out air compliance
management programs. All AFS users must ensure that the AFS application and its data are protected from loss,
misuse, and unauthorized access or modification.
There are certain security practices and procedures that should be followed to minimize the potential misuse or
damage to the AFS database. Some of these include:
. Be familiar with the security policies and practices involving the AFS application, especially
those for confidential or sensitive information.
. Maintain security for the application by correctly using established security mechanisms (use
of unique user ID and password) and practices when accessing the AFS application.
. Do not attempt to view, change, or delete data unless you are authorized to do so.
. Do not use your system privileges to obtain data/files or run applications for anyone who is not
authorized to view or use data that are sensitive.
. Be alert to potential threats to corrupt or destroy the AFS application and database.
Ensure that no one person has sole access to, or control over, AFS information and processing
resources.
. Guard user ID and password. Do not loan out to others.
III. GUIDELINES FOR HANDLING ENFORCEMENT-SENSITIVE DATA
It is paramount that any sensitive information (e.g., enforcement, compliance) in the AFS application is protected
from unauthorized access. Keep in mind the following:
Be sure to provide only authorized personnel with sensitive data (whether the data are on your
screen, on paper or in an electronic file).
. When viewing or processing confidential or sensitive data, be sure the PC is in a non-traffic
area and that only persons authorized to see the data are in the area.
. Protect all documents, reports and files containing sensitive data. Be sure that they are labeled
"ENFORCEMENT-SENSITIVE."
. Destroy sensitive documents by shredding when finished with them.
. Safeguard sensitive data. Do not store to your hard drive, safeguard your diskettes.
Log off your computer when you are away from your work station!
. Lock up or put away sensitive data.
IV. PROTECTING YOUR PASSWORD
Review the following tips for protecting your password:
Control access to your PC. Log out whenever you leave your machine.
Change your application password every 90 days. Use at least 8 alphanumeric characters in
your application password.
. Do not use family names, birthdays, sports teams' names, or words that can be found in the
dictionary.
. Do not use consecutive keys on a keyboard or all the same character.
Use new passwords. Do not use the last 8 versions of your password.
If you believe your password has been compromised, change it immediately.
. Memorize your password rather than writing it down somewhere.
Notify the AFS System Administrator (Betsy Metcalf 202-564-5962) or AFS Security Manager (Akachi Imegwu
202-564-0045) immediately of security incidents. Notify your Regional AFS Compliance Manager when you no
longer need access to the application.
V. LOGGING IN FOR THE FIRST TIME
-------
This initial log in may require extra time to understand the various information displays. However, once you have
successfully logged in, you may find it useful to keep in mind the following in reference to your JCL (Java Control
Language) default:
ACCOUNT
FIMAS
TIME (MMMM)
TIME (SS)
PRIORITY CODE
MSGCLASS
NUMBER OF COPIES
FORM NUMBER
ROOM/BIN NUMBER
HOLD OUTPUT? (Y/N)
PRINTER SITE ID
Account Code: This is your NCC account code (Ex: AIRS, YNYA, etc)
FIMAS ID: use "AFSCP"
Time: Enter 6:40 for six minutes and 40 seconds
Priority: Use ' 1' unless approved by your Regional AFS Compliance Manager to use a different priority code.
2 (Prime time; 7:00am - 7:00pm Mon-Fri)
1 (Overnight; 7:00pm - 7:00am Mon - Fri)
0 (Weekend; Fri. 7:00pm - Mon 7:00am)
MSGCLASS: This is usually "A"
Number of Copies: "1"
Form Number: This is usually blank
Room/Bin Number: Take your User ID and put an 'M' in front of it. Ex: MIAJ, MKGQ, etc
Hold Output: "Y"
Printer Site ID: enter 'HOLD' or 'R255'
Please call your AFS Compliance Manager if you need assistance with your initial log in!
VI. TRAINING MOVIE ON THE WEB: AFS RULES OF BEHAVIOR
Recently we have launched an AFS training course through the National Enforcement Training Institute (NETI)
web portal which will allow you to watch a training film online explaining these rules. Please see below for
viewing instructions.
Instructions for Viewing AFS Rules of Behavior Training Film
Please keep in mind the following as you prepare to view the courses 1) The training movie is best viewed if your
desktop resolution is set to 1280 x 1024 pixels; 2) The courses have a sound component to them and you will need
to adjust the volume depending on your surroundings.
1. Go to www.netionline .com and logon with your account/password. If you don't have a NETI account and
password, click the link, complete the necessary information, and submit. You will
receive a response promptly.
2. After logging in, select the link under the "Quick Links" heading in the upper left of the website.
3. Find the AFS 901: Air Facility System (AFS) Training course under the "Web Based Courses" heading
towards the bottom of the page.
4. Select the link. You will receive a confirmation message upon completion of registration.
5. After confirmation, go to the link under the "Menu" heading on the left.
6. Find the AFS 901: Air Facility System (AFS) Training under the "My Classrooms" heading.
-------
7. Select the
8. Select the
9. Select the
link.
link under the "Course Activities" heading.
course from the "AFS Training Movie Main Menu" heading. The course
will launch in a separate window.
Your opinion is important to us! After viewing the film(s) please provide your comments and suggestions.
VII. SUMMARY REMARKS
This information was compiled to assure that the contents and integrity of AFS data will be secure. In order to
maintain security for the data provided in AFS, we suggest that the guidelines above be followed. The security
measures that have been established are designed to protect the data that State and local agencies submit, while at
the same time protecting the computer systems that EPA operates.
Any questions concerning the above information should be referred to Akachi Imegwu, AFS Security Manager, at
(202) 564-0045.
VIII. USEFUL LINKS AND CONTACTS
CONTACTS
Your Regional AFS Compliance Managers will be your main point of contact for information on AFS.
EPA REGION
1
2
2
3
4
5
6
7
8
8
9
9
10
CONTACT NAME
Beth Kudarauskas
Steve Carrea
Phillip Ritz
Louvinia Madison-Glenn
Ahmed Amanulah
Lisa Holscher
Pam Elder-Schweers
Joe (Hugh) McCullough
Jocelyn Hoffman
Jeffrey Mosal
Linda Barajas-Porter
John Borton
Laurie Krai
PHONE
617918-1564
212-637-3498
212-637-4064
215-814-5704
404-562-9209
312-866-6818
214-665-7463
913-551-7191
303-312-6232
303-312-6802
415-947-4131
415-972-3985
206-553-1868
Also keep note of the AFS Help Line, which is available Mon - Fri from 8:15am to 5:00pm Eastern time for
questions concerning connectivity, data entry or data extraction at 1-800-367-1044.
The NCC Support Line is available for further technical assistance at: 1-866-411-4372.
DOCUMENTATION
Navigate to the AFS web site at: http://www.epa.gov/compliance/data/svstems/air/afssvstem.html for the following
documents:
AFS Business Rules
-------
AFS Data Dictionary
Universal Interface
A comprehensive listing of national and regional action types
News on Upcoming Events
Clean Air Act Enforcement
and morel
The following additional websites may prove useful in your search for information:
Enforcement and Compliance History Online (ECHO): http://www.epa.gov/echo/
Online Targeting Information System (OTIS): http://www.epa.gov/idea/otis/
EPA's Enforcement and Compliance Assurance: http://www.epa.gov/compliance/index.html
EPA's central Facility Registry System (FRS): http://www.epa.gov/enviro/html/fii/fii_queryJava.html
TRC website (EPA Contractor) https://pops.trcsolutions.com/pops (login id=afsuser, password=airs, domain=client)
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Appendix 7
Acronyms Used in this Document
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-------
Acronyms used in this Document
Note: Items listed in italicized, bold print are acronyms specific to the Air Facility System (AFS)
AFS: Air Facility System
APC1: Air program Code
APO: Administrative Penalty Order
ASPN: Permit Number
AST1: Air Program Operating Status
CAA:
CAPP:
CASN:
CCB:
CEM:
CFC:
CMS:
CNTY:
COFA:
CMSC:
CMS/:
CYNM:
DADS: HPV Discovery Action Type description
DADT: HPV Discovery Date
DATP: HPV Discovery Action Type
DCL1: Default Plant Classification
DTA1: Date Achieved
Clean Air Act
Chemical Abstract Service Number
Chemical Abstract Service Number
Configuration Control Board
Continuous Emission Monitor
Chlorofluorocarbons
Compliance Monitoring Strategy
County Code
Closeness of Fit Analysis
Compliance Monitoring Strategy
Category
Compliance Monitoring Strategy
Frequency Indicator
City Name
FACIL: Facility
FCE: Full Compliance Evaluation
FESOP: Federally Enforceable State Operating
Permit
FIP: Federal Information Procedures System
FRS: Facility Registry System
FTP: File Transfer Protocol
GO W: Governmental Facility Code
GPRA: Government Results and Performance Act
HAP:
HPV:
I
ICR:
ICIS:
Hazardous Air Pollutants
High Priority Violators
Information Collection Request
Integrated Compliance Information System
J
LCON: Local Control Region
MACT: Maximum Achievable Control Technology
MDR: Minimum Data Requirements
NAAQS: National Ambient Air Quality Standards
NAICS: North American Industrial Classification
System
NESHAP: National Emission Standard for
Hazardous Air Pollutants
NOV: Notice of Violation
NSPS: New Source Performance Review
NSR: New Source Review
OAQPS: Office of Air Quality Planning Standards
OECA: Office of Enforcement and Compliance
Assurance
OTIS: Online Targeting and Information System
Penalty Amount
Permit Action Type
CDS Plant ID
Partial Compliance Evaluation
Permit Date Event Achieved
Pollutant Code
Pollutant Code
Permit Category
Plant Name
Permit Program Data Elements
Prevention of Significant Deterioration
PAM1:
PATY:
PCDS:
PCE:
PDEA:
PLAP:
PLC1:
PMTC:
PNME:
PPDE:
PSD:
Version dated 6/23/06
-------
RATA: Relative Accuracy Test Audit
RD08: Regional Data Element 8 (aka RD81)
RD16: Regional Data Element 16
RD81: Regional Data Element 8
RECAP: Reporting for Enforcement and
Compliance Assurance Priorities
RMRR: Routine Maintenance, Repair and
Replacement
RSC1: Results Code
SA TN: State Pollutant Attainment Indicator
SCAP: State Pollutant Compliance Status
SCLP: State Pollutant Classification Code
SCL1: State Classification Code
SCNC: SIC/NAICS
SCSC: State-County-Plant ID
SEP: Supplemental Environmental Project
SIC: Standard Industrial Classification
SIC1: Standard Industrial Classification Code
SIP: State Implementation Plan
SM: Synthetic Minor
SPT1: Subpart
STAB: State Abbreviation
STRS: State Registration Number
STRT: Street Address
STTE: State Code
SV: Significant Violator
T&A: Timely and Appropriate
TAR: Tribal Authorization Plan
TIP: Tribal Implementation Plan
VTP1: Violation Type Code(s)
VPL1: Violating Pollutants)
ZIPC: Zip Code
Version dated 6/23/06
-------
Appendix 8
Change/Update Request Form
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-------
AFS
DATE:
TO:
FROM:
mail
CHANGE/UPDATE REQUEST FORM
EPA Regional AFS Compliance Manager
e Nam
Title
Agency
s Addres
Phone
I would like to request the following change/update to the AFS Business Rules
Compendium:
(please describe the change, include the appropriate page number, version of the
document you are using, and appropriate section of the document for your
changes/update/additions)
Page 1 of 1
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Appendix 9
AFS Schedule of Monthly Utilities
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January 2009
Federal Holiday
NIGHTLY BATCH
CDE
DELOLDCDE
BATCH CLEANUP
HPV CLEANUP
NIGHTLY BATCH
CDE
DELOLDCDE
NIGHTLY BATCH
CDE
DELOLDCDE
NIGHTLY BATCH
CDE
DELOLDCDE
NIGHTLY BATCH
CDE
DELOLDCDE
NIGHTLY BATCH
CDE
DELOLDCDE
BATCH CLEANUP
HPV CLEANUP
NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH BATCH CLEANUP
CDE CDE CDE CDE CDE HPV CLEANUP
DELOLDCDE DELOLDCDE DELOLDCDE DELOLDCDE DELOLDCDE
Federal Holiday
NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH BATCH CLEANUP
CDE CDE CDE CDE HPV CLEANUP
DELOLDCDE DELOLDCDE DELOLDCDE DELOLDCDE
NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH NIGHTLY BATCH
CDE CDE CDE CDE CDE
DELOLDCDE DELOLDCDE DELOLDCDE DELOLDCDE DELOLDCDE
UNK-GEN&UNGEN COMPL HISTORY
BATCH CLEANUP
HPV CLEANUP
NEW CMS FLAGS FOR FYO? SHOULD BE LOADED INTO AFS BY JANUARY 31, 200?
-------
february 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY THURSDAY
FRIDAY
SATURDAY
1
8
15
22
1 mar.
notes:
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
Federal Holiday
WASHINGTON'S BD
23
NIGHTLY BATCH
CDE
DELOLDCDE
2
3
NIGHTLY BATCH
CDE
DELOLDCDE
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
3
4
NIGHTLY BATCH
CDE
DELOLDCDE
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
4
5
NIGHTLY BATCH
CDE
DELOLDCDE
12
NIGHTLY BATCH
CDE
DELOLDCDE
19
NIGHTLY BATCH
CDE
DELOLDCDE
26
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
5
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
6
7
BATCH CLEANUP
HPV CLEANUP
14
BATCH CLEANUP
HPV CLEANUP
21
BATCH CLEANUP
HPV CLEANUP
28
BATCH CLEANUP
HPV CLEANUP
-------
march 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY THURSDAY
FRIDAY
SATURDAY
1
8
15
22
29
notes:
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
QTRLYCOMPL
3
NIGHTLY BATCH
CDE
DELOLDCDE
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
AFS NATL WS
24
NIGHTLY BATCH
CDE
DELOLDCDE
31
NIGHTLY BATCH
CDE
DELOLDCDE
FY092NDQTR
4
NIGHTLY BATCH
CDE
DELOLDCDE
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
AFS NATL WS
25
NIGHTLY BATCH
CDE
DELOLDCDE
1 Apr.
5
NIGHTLY BATCH
CDE
DELOLDCDE
12
NIGHTLY BATCH
CDE
DELOLDCDE
19
NIGHTLY BATCH
CDE
DELOLDCDE
AFS NATL WS
26
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
2
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
3
7
BATCH CLEANUP
HPV CLEANUP
14
BATCH CLEANUP
HPV CLEANUP
21
BATCH CLEANUP
HPV CLEANUP
28
BATCH CLEANUP
HPV CLEANUP
4
-------
april 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
29 mar.
5
12
19
26
notes:
30
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
31
7
NIGHTLY BATCH
CDE
DELOLDCDE
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
1
NIGHTLY BATCH
CDE
DELOLDCDE
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
3
NIGHTLY BATCH
CDE
DELOLDCDE
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
1 may
4
BATCH CLEANUP
HPV CLEANUP
11
BATCH CLEANUP
HPV CLEANUP
18
BATCH CLEANUP
HPV CLEANUP
25
BATCH CLEANUP
HPV CLEANUP
2
-------
may 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
26 apr.
3
10
17
24
31
27
4
NIGHTLY BATCH
CDE
DELOLDCDE
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
Federal Holiday
MEMORIAL DAY
1 Jun.
28
5
NIGHTLY BATCH
CDE
DELOLDCDE
12
NIGHTLY BATCH
CDE
DELOLDCDE
19
NIGHTLY BATCH
CDE
DELOLDCDE
26
NIGHTLY BATCH
CDE
DELOLDCDE
2
29
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
3
30
7
NIGHTLY BATCH
CDE
DELOLDCDE
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
4
1
NIGHTLY BATCH
CDE
DELOLDCDE
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
5
2
BATCH CLEANUP
HPV CLEANUP
9
BATCH CLEANUP
HPV CLEANUP
16
BATCH CLEANUP
HPV CLEANUP
23
BATCH CLEANUP
HPV CLEANUP
30
BATCH CLEANUP
HPV CLEANUP
6
notes:
FY09 DATA (10/10/2008-03/31/2008) DUE IN1O AFS BY 05/31/2008
-------
June 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
31
7
14
21
28
notes:
1
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 MID YEAR
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
QTRLYCOMPL
2
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 MID YEAR
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
3
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 MID YEAR
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
1 jul.
4
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 MID YEAR
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
2
5
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 MID YEAR
12
NIGHTLY BATCH
CDE
DELOLDCDE
19
NIGHTLY BATCH
CDE
DELOLDCDE
26
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
3
6
BATCH CLEANUP
HPV CLEANUP
13
BATCH CLEANUP
HPV CLEANUP
20
BATCH CLEANUP
HPV CLEANUP
27
BATCH CLEANUP
HPV CLEANUP
4
-------
July 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
28 jun.
5
12
19
26
notes:
29
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
30
7
NIGHTLY BATCH
CDE
DELOLDCDE
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
1
NIGHTLY BATCH
CDE
DELOLDCDE
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
3
Federal Holiday
INDEPENDENCE HOLIDAY
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
31
NIGHTLY BATCH
CDE
DELOLDCDE
4
BATCH CLEANUP
HPV CLEANUP
INDEPENDENCE DAY
11
BATCH CLEANUP
HPV CLEANUP
18
BATCH CLEANUP
HPV CLEANUP
25
BATCH CLEANUP
HPV CLEANUP
1 aug.
-------
august 2009
SUNDAY MONDAY TUESDAY WEDNESDAY THURSDAY
FRIDAY
SATURDAY
26 jul.
2
9
16
23
30
27
3
NIGHTLY BATCH
CDE
DELOLDCDE
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
31
NIGHTLY BATCH
CDE
DELOLDCDE
28
4
NIGHTLY BATCH
CDE
DELOLDCDE
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
NIGHTLY BATCH
CDE
DELOLDCDE
1 sep.
29
5
NIGHTLY BATCH
CDE
DELOLDCDE
12
NIGHTLY BATCH
CDE
DELOLDCDE
19
NIGHTLY BATCH
CDE
DELOLDCDE
26
NIGHTLY BATCH
CDE
DELOLDCDE
2
30
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
3
31
7
NIGHTLY BATCH
CDE
DELOLDCDE
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
4
1
BATCH CLEANUP
HPV CLEANUP
8
BATCH CLEANUP
HPV CLEANUP
15
BATCH CLEANUP
HPV CLEANUP
22
BATCH CLEANUP
HPV CLEANUP
29
BATCH CLEANUP
HPV CLEANUP
5
notes:
-------
September 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
30 aug.
6
13
20
27
31
7
Federal Holiday
LABOR DAY
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
1
NIGHTLY BATCH
CDE
DELOLDCDE
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
QTRLY COMPL
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
3
NIGHTLY BATCH
CDE
DELOLDCDE
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
1 oct.
4
NIGHTLY BATCH
CDE
DELOLDCDE
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
2
5
BATCH CLEANUP
HPV CLEANUP
12
BATCH CLEANUP
HPV CLEANUP
19
BATCH CLEANUP
HPV CLEANUP
26
BATCH CLEANUP
HPV CLEANUP
3
notes:
FYO? DATA (10/1/2008-07/30/200?) DUE IN AFS BY 11/30/200?
-------
October 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
27 sep.
4
11
18
25
notes:
28
5
NIGHTLY BATCH
CDE
DELOLDCDE
12
Federal Holiday
COLUMBUS DAY
19
NIGHTLY BATCH
CDE
DELOLDCDE
26
NIGHTLY BATCH
CDE
DELOLDCDE
29
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
30
7
NIGHTLY BATCH
CDE
DELOLDCDE
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-UNGEN ONLY
1
NIGHTLY BATCH
CDE
DELOLDCDE
Historic CMS
FY10 BEGINS
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
3
BATCH CLEANUP
HPV CLEANUP
10
BATCH CLEANUP
HPV CLEANUP
17
BATCH CLEANUP
HPV CLEANUP
24
BATCH CLEANUP
HPV CLEANUP
31
BATCH CLEANUP
HPV CLEANUP
-------
november 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY THURSDAY
FRIDAY
SATURDAY
1
8
15
22
29
notes:
2
NIGHTLY BATCH
CDE
DELOLDCDE
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
3
NIGHTLY BATCH
CDE
DELOLDCDE
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-UNGEN ONLY
1 dec.
4
NIGHTLY BATCH
CDE
DELOLDCDE
11
Federal Holiday
VETERAN'S DAY
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
2
5
NIGHTLY BATCH
CDE
DELOLDCDE
12
NIGHTLY BATCH
CDE
DELOLDCDE
19
NIGHTLY BATCH
CDE
DELOLDCDE
26
Federal Holiday
THANKSGIVING
3
6
NIGHTLY BATCH
CDE
DELOLDCDE
13
NIGHTLY BATCH
CDE
DELOLDCDE
20
NIGHTLY BATCH
CDE
DELOLDCDE
27
NIGHTLY BATCH
CDE
DELOLDCDE
7
BATCH CLEANUP
HPV CLEANUP
14
BATCH CLEANUP
HPV CLEANUP
21
BATCH CLEANUP
HPV CLEANUP
28
BATCH CLEANUP
HPV CLEANUP
5
-------
december 2009
SUNDAY
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
SATURDAY
29 nov.
6
13
20
27
notes:
30
7
NIGHTLY BATCH
CDE
DELOLDCDE
14
NIGHTLY BATCH
CDE
DELOLDCDE
21
NIGHTLY BATCH
CDE
DELOLDCDE
28
NIGHTLY BATCH
CDE
DELOLDCDE
UNK-GEN&UNGEN
1
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 EOY REVIEW
8
NIGHTLY BATCH
CDE
DELOLDCDE
15
NIGHTLY BATCH
CDE
DELOLDCDE
22
NIGHTLY BATCH
CDE
DELOLDCDE
29
NIGHTLY BATCH
CDE
DELOLDCDE
COMPL HISTORY
2
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 EOY REVIEW
9
NIGHTLY BATCH
CDE
DELOLDCDE
16
NIGHTLY BATCH
CDE
DELOLDCDE
23
NIGHTLY BATCH
CDE
DELOLDCDE
30
NIGHTLY BATCH
CDE
DELOLDCDE
QTRLY COMPL
3
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 EOY REVIEW
10
NIGHTLY BATCH
CDE
DELOLDCDE
17
NIGHTLY BATCH
CDE
DELOLDCDE
24
NIGHTLY BATCH
CDE
DELOLDCDE
31
NIGHTLY BATCH
CDE
DELOLDCDE
4
NIGHTLY BATCH
CDE
DELOLDCDE
FY09 EOY REVIEW
11
NIGHTLY BATCH
CDE
DELOLDCDE
18
NIGHTLY BATCH
CDE
DELOLDCDE
25
Federal Holiday
CHRISTMAS
1 Jan.
5
BATCH CLEANUP
HPV CLEANUP
12
BATCH CLEANUP
HPV CLEANUP
19
BATCH CLEANUP
HPV CLEANUP
26
BATCH CLEANUP
HPV CLEANUP
2
-------
Appendix 10
AFS Contingency Planning Data
Entry Forms
-------
INSTRUCTIONS AND BACKGROUND FOR CONTINGENCY DATA ENTRY FORM
BACKGROUND
The Air Facility System (AFS) contains compliance, enforcement and permit data for stationary sources of air pollution
regulated by the US EPA and state and local air pollution agencies. This information is used by the environmental
regulatory community to track the compliance of stationary sources with various programs regulated under the Clean Air
Act.
In the event of a disaster resulting in AFS being inaccessible nationally, a user should, as much as is practicable:
1. Notify the relevant personnel
2. Ensure that data is recorded as is detailed in the AFS Contingency Data Entry Form
3. Return the recorded data to EPA at scheduled intervals
In order to maintain a continuity of operations, the following workbook containing 12 worksheets (each worksheet
representing an AFS record) has been developed to facilitate the recording of AFS data in the event of a disaster. It is
recommended that this worksheet be printed out so that a hardcopy is available in the event that your computer
system is unavailable.
INSTRUCTIONS FOR COMPLETING THIS WORKBOOK
The top of each worksheet includes a additional information in the upper left hand. Please read the notes for specific
information pertaining to that worksheet. And be sure to enter in all of the Minimum Data Requirements (MDRs). The
following worksheets are enclosed in this workbook:
Compliance Enforcement (worksheets prefixed with "CE")
Plant General
Air Program
Air Program Pollutant
Action
Permits (worksheets prefixed with "P")
Permit
Permit Event
Continuous Emissions Monitoring (worksheets pre-fixed with "OEM")
Point
Air Program
Monitor
Excess Emission Report
Compliance Monitoring Strategy (worksheets titled "CMS")
CMS
Comment (worksheets titled "Comment")
Comment
CONTACTS
Akachi Imegwu
AFS Security Manager
202-564-0045
Betsy Metcalf
AFS System Administrator
202-564-5962
Helpline: 1-800-367-1044
Website: http://www.epa.gov/compliance/data/systems/air/afssystem.html
Technical Support Mailbox: afs-support@epa.gov
Please be sure to keep in contact with your respective Regional AFS Compliance Manager
1 of 17
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
The Plant General Record contains
identification information on a source.
Use the FIPS Code for entering the State and
County code.
Fields in Yellow contain minimum data
requrements.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
PNME-Plant Name
STRT - Street Address
CYCD - City Code
CYNM-- City Name
ZIPC-Zip Code
SIC1 - Primary SIC Code
GOVT - Governmental Facility Code
NIC1 - NAICS Code
STRS - State Registration Number
LCON - Local Control Region
PAFS-AFS ID
STTE
CNTY
PCDS
PNME
STRT
CYCD
CYNM
ZIPC
SIC1
GOVT
NIC1
STRS
LCON
PAFS
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
The Air Program record contains information on
the regulatory program of the Clean Air Act
that is applicable to a source
Fields in yelloi
.requirements
contain minimum data
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
APC1 -Air Program Code
AST1 - Air Program Operating Status
SPT1 - CFR Subparts 1 thru 12
STTE
CNTY
PCDS
APC1
AST1
SPT1
CFR SP 1
SPT1
CFR SP 2
SPT1
CFR SP 3
SPT1
CFR SP 4
SPT1
CFR SP 5
SPT1
CFR SP 6
SPT1
CFR SP 7
SPT1
CFR SP 8
SPT1
CFR SP 9
SPT1
CFRSP10
SPT1
CFRSP11
SPT1
CFRSP12
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
Each source in AFS is required to
have at least one air program and
one air program pollutant. Every
applicable air program for a
source must have at least one air
program pollutant.
Fields in yellow contain minimum
data requirements.
ECAP, ECLP, & EATT will be
populated by the EPA.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
APC1 -Air Prog ram
PLAP - Pollutant
CAPP - Chemical Abstract Service Number
SCAP - State Compliance Status
SCLP-- State Class
SATT - State Attainment Indicator
ECAP - EPA Compliance Status
ECLP - EPA CLass
EATT - EPA Attainment Indicator
STTE
CNTY
PCDS
APC1
PLAP
CAPP
SCAP
SCLP
SATT
ECAP
ECLP
EATT
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
ANU1 -Action Number
KAN1 - Key Action Number
ACS1 -Air Program Code (1 thru 6)
ATP1 -Action Type
DTS1 - Date Scheduled
DTA1 -Date Achieved
PAM1 - Penalty Amount
RSC1 - Results Code
SCC1 - Staff Code
PLC1 - Pollutant
CAA1 -CAS Number
RD81 - RDE 8
R161 -RDE 16
LDC1 - Lead Agency
VID1 -Violating Identifier
VTP1 -Violation Type Code (1 thru 7)
VPL1 -Violating Pollutant (1 thurS)
NOTE
The Action record contains information on the various
activities that have taken place at a source. The fields
in Yellow contain minimum data requirements.
Further notes are as follows:
-Key Action Number (KAN1) is an MDR for violation
pathways.
-Results Code (RSC1) Pass/Fail/Pending (PP/FF/99)
codes are reported for Stack Test actions.
-RD08 Certification Deviations (RD81) EPA reports
into AFS unless otherwise negotiated. Deviations are
reported by EPA: Y= Yes, N=No, or a number of
deviations reported may be entered. Note:
Compliance status is to be reported in the Results
Code field: MC=ln Compliance, MV= In Violation, MU
= Unknown.
-Date Scheduled ( DTS1) Due Date of a Title V ACC
will be reported as Date Scheduled on the "Title V
ACC Due/Received by EPA" action, and is not
enforcement sensitive.
MINIMUM DATA REQUIREMENTS - MINIMUM REPORTABLE ACTIONS
Actions are to be Reported within 60 Days of Event as reported in the Date
Achieved (DTA1) field of the action record for state and local agencies [with a
minimum upload of six (6) times per year].
Informal Enforcement Actions: Notice of Violation(s)
Formal Enforcement Actions: Administrative Order(s) and Assessed Penalties,
Consent Decrees and Agreements, Civil and Criminal Referrals, Civil and Criminal
Actions
Title V Annual Compliance Certification [ACC] Reviewed: includes Results
Codes for ACC reviews: in compliance (MC), in violation (MV) and unknown (MU).
ACC deviations(s) will be indicated in RD08 for EPA reviews (and state reviews as
negotiated).
HPV Violation Discovered: Linked actions are FCEs, PCEs, Stack Tests
(Observed or Reviewed), Title VACCs, Stack Test Notification Receipt
HPV Addressing Actions: Linked actjons include but are not limited to
State/EPA Civil or Criminal Referrals, State/EPA Civil or Criminal Actions,
Administrative Orders, Consent Decrees, Source Returned to Compliance by
State/EPA with no Further Action Required.
HPV Resolving Actions: Linked actions include but are not limited to Violation
Resolved, Closeout Memo Issued, Source Returned to Compliance by State/EPA
with no Further Action Required.
Full Compliance Evaluations (On or Off Site)
Stack Tests: Pass/Fail/Pending codes (PP/FF/99) are reported in the results
code field, pending codes must be updated within 120 days.
Title V Annual Compliance Certification Due/Received: Reported by EPA
unless otherwise negotiated. The Due Date of a Title V ACC will be reported as
Date Scheduled on the "Title V ACC Due/Received by EPA" action, and is not
enforcement sensitive.
Investigations: EPA Investigation Initiated (started) and State/EPA Investigation
Conducted (finished). State Investigation Initiated is added for optional use. EPA
and State Investigation Initiated (started) action types are enforcement sensitive.
STTE
CNTY
PCDS
ANU1
KAN1
ACS1
AP Code 1
ACS1
AP Code 2
ACS1
AP Code 3
ACS1
AP Code 4
ACS1
AP Code 5
ACS1
AP Code 6
ATP1
DTS1
DTA1
PAM1
RSC1
SCC1
PLC1
CAA1
RD81
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
SITE
CNTY
PCDS
ANU1
KAN1
ACS1
AP Code 1
ACS1
AP Code 2
ACS1
AP Code 3
ACS1
AP Code 4
ACS1
AP Code 5
ACS1
AP Code 6
ATP1
DTS1
DTA1
PAM1
RSC1
SCC1
PLC1
CAA1
RD81
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
R161
LDC1
VID1
VTP1
Type
Codel
VTP1
Type Code
2
VTP1
Type
Code 3
VTP1
Type Code
4
VTP1
Type Code
5
VTP1
Type Code
6
VTP1
Type
Code?
VPL1
Pollutant
1
VPL1
Pollutant 2
VPL1
Pollutant
3
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
R161
LDC1
VID1
VTP1
Type
Codel
VTP1
Type Code
2
VTP1
Type
Code 3
VTP1
Type Code
4
VTP1
Type Code
5
VTP1
Type Code
6
VTP1
Type
Code?
VPL1
Pollutant
1
VPL1
Pollutant 2
VPL1
Pollutant
3
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
AFS Compliance Monitoring Strategy
record contains information on stationary
source air compliance monitoring
programs.
Fields in Yellow contain minimum data
requirements.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS-Plant ID
CMSC - Source Category
CMSI - CMS Min Frequency Indicator
CMYA - Fiscal Year of FCE A
CMOA - On Site Visit Indicator A
CMYB - Fiscal Year of FCE B
CMOB - On Site Visit Indicator B
CMYC - Fiscal Year of FCE C
CMOC - On Site Visit Indicator C
CMYD - Fiscal Year of FCE D
CMOD - On Site Visit Indicator D
CMYE - Fiscal Year of FCE E
CMOE - On Site Visit Indicator E
CM19 - CMS Comment
STTE
CNTY
PCDS
CMSC
CMSI
CMYA
CMOA
CMYB
CMOB
CMYC
CMOC
CMYD
CMOD
CMYE
CMOE
CM19
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
The following fields are necessary for a
complete permit draft record; STTE,
ASPN, PMTC& PAFS.
TABLE DESCRIPTION
STTE - State Code
ASPN - Permit ID
PMTC - Category
PMFD - Effective Date
ASRD - Mod/Renewal Effective Date
PMXD - Expiration Date (Projected)
AAD1 - Permitting Authority Data Element
CNTY - County
PAFS-AFS ID
STTE
ASPN
PMTC
PMFD
ASRD
PMXD
AAD1
CNTY
PAFS
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
To ensure a full and complete permit event
record ALL the fields in the table are
necessary. Please fill out completely.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PAFS-AFS ID
PAPN - Permit ID
PATY - Event Type
PACN - Event Number
PDEA - Date Achieved
PARC - Results
STTE
CNTY
PAFS
PAPN
PATY
PACN
PDEA
PARC
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
To ensure a full and complete point general
record ALL the fields in the table are necessary.
Please fill out completely.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
PNUM - Point ID
CEID-Point C/E ID
DSC3 - Point Description
STTE
CNTY
PCDC
PNUM
CEID
DSC3
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
The following fields are necessary for a complete point air
program record; STTE, CNTY, PCDS, PNUM, CEID, APC3,
SCA3 & AST3. Please fill out completely.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
PNUM - Point ID
CEID-Point C/E ID
APC3 - Point Air Program
SPT3 - Point Level Sub Part (1 thru 12)
SCA3 - Point Compliance Status
AST3 - Point Operating Status
STTE
CNTY
PCDS
PNUM
CEID
APC3
SPT3
Sub Part 1
SPT3
SubPart 2
SPT3
SubPart 3
SPT3
SubPart 4
SPT3
SubPart 5
SPT3
SubPart 6
SPT3
SubPart 7
SPT3
SubPart 8
SPT3
SubPart 9
SPT3
SubPart 10
SPT3
Sub Part 11
SPT3
SubPart 12
SCA3
AST3
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NONE
The following fields are necessary for a
complete monitor record; STTE, CNTY,
PCDS, PNUM, CEID, & CHNM, as they are
used to identify the equipment. In addition
please enter information for at least ONE of
the following fields to provide descriptive
information about the equipment: MTMR,
MTMN, MTSN, MTRC, CEMA, PEML,
MTID, PSTD, PSTS &/orCEDT.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
PNUM - Point ID
CEID-Point C/E ID
CHNM-Channel Number
MTMR Manufacturer
MTMN - Model Number
MTSN - Serial Number
MTRC - Requirement Code
CEMA - Enforcement Agency
PEML - Permissible Limit
MTID - Installation Date
PSTD - Performance Specification Date
PSTS - Performance Specification Status
CEDT - Certification Date
STTE
CNTY
PCDS
PNUM
3EIC
CHNM
MTMR
MTMN
MTSN
MTRC
CEMA
PEML
MTID
PSTC
PSTS
CEDT
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
The following fields are necessary for a complete
excess emission report record; STTE, CNTY,
PCDS, PNUM, CEID, CHNE & RQT3. In addition
please enter information for at least ONE of the
following fields to provide descriptive information
about the emission; ACSP, TSOT, TIMC, STSH,
CLSB, UNEE, CLEF, CLMU, PPRO, PPRU,
INEE, FUPB, OKEE, MTEM, MNEM, CALB,
UNMD, OKMD&/OMNMD.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
PNUM - Point ID
CEID-Point C/E ID
CHNE - Channel Number
RQT3 - Report Quarter
ACSP - EER Air Program (1 thru 6)
TSOT - Total Source Operating Time
TIMC - Time Period Code
STSH - Start-up / Shut-down
CLSB - Cleaning / Soot-blowing
UNEE - Unknown Excess
CLEF - Control Equipment Failure
CLMU - Control Equipment Malfunction Unacceptable
PPRO - Process Problems
PPRU - Process Problems Unacceptable
INEE - Number of Incidents of Excess Emissions
FUPB-Fuel Problems
OKEE - Other Known Excesses
MTEM - Monitor Equipment Malfunction
MNEM - Non-Monitor Equipment Malfunction
CALB - Calibration
UNMD - Unknown Monitor Downtime
OKMD - Other Known Monitor Downtime
INMD - Number of Incidents of Monitor Downtime
STTE
CNTY
PCDS
PNUM
CEID
CHNE
RQ
YEAR
T3
QTR
ACSP
EER AIR
PRGM1
ACSP
EER AIR
PRGM2
ACSP
EER AIR
PRGM3
ACSP
EER AIR
PRGM4
ACSP
EER AIR
PRGM5
ACSP
EER AIR
PRGM6
TSOT
TIMC
STSH
CLSB
UNEE
CLEF
CLMU
PPRO
PPRU
INEE
FUPB
OKEE
MTEM
MNEM
CALB
UNMD
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PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
OKMD
INMD
-------
PLANT GENERAL WORKSHEET - CONTINGENCY DATA ENTRY FORM
NOTE
If the comment is against the whole plant
then an action # is NOT needed. If the
comment is for a specific action all fields
are necessary.
TABLE DESCRIPTION
STTE - State Code
CNTY - County Code
PCDS - Plant ID
ANU1 -Action Number
CNU1 -Comment Number
COM1 - Comment
STTE
CNTY
PCDS
ANU1
CNU1
COM1
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AFS Contingency Data Entry Form - Notes
BACKGROUND
The Air Facility System (AFS) contains compliance, enforcement and permit data for stationary sources of air pollution regulated by
the US EPA and state and local air pollution agencies. This information is used by the environmental regulatory community to track
the compliance of stationary sources with various programs regulated under the Clean Air Act.
In the event of a disaster resulting in AFS being inaccessible nationally, a user should, as much as is practicable :
1. Notify the relevant personnel
2. Ensure that data is recorded as is detailed in the AFS Contingency Data Entry Form
3. Return the recorded data to EPA at scheduled intervals
In order to maintain a continuity of operations, the following workbook containing 12 worksheets ( each worksheet representing an AFS
record) has been developed to facilitate the recording of AFS data in the event of a disaster. It is recommended that this
worksheet be printed out so that a hardcopy is available in the event that your computer system is unavailable.
INSTRUCTIONS FOR COMPLETING THIS WORKBOOK
The top of each worksheet includes a additional information in the upper left hand. Please read the notes for specific information
pertaining to that worksheet. And be sure to enter in all the the Minimum Data Requirements (MDRs). The following worksheets are
enclosed in this workbook:
Compliance Enforcement (worksheets prefixed with "CE")
Plant General
Air Program
Air Program Pollutant
Action
Permits (worksheets prefixed with "P")
Permit
Permit Event
Continuous Emissions Monitoring (worksheets pre-fixed with "CEM")
Point
Air Program
Monitor
Excess Emission Report
Compliance Monitoring Strategy (worksheets titled "CMS")
CMS
Comment (worksheets titled "Comment")
Comment
CONTACTS
Akachi Imegwu
AFS Security Manager
202-564-0045
Betsy Metcalf
AFS System Administrator
202-564-5962
Helpline: 1-800-367-1044
Website: http://www.epa.gov/compliance/data/systems/air/afssystem.html
Technical Support Mailbox: afs-support@epa.gov
Please be sure to keep in contact with your respective Regional AFS Compliance Manager
1 of 13
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AFS Contingency Data Entry Form - Notes
Compliance Enforcement - Plant General Record
This table contains general information describing the plant and its physical location.
Data Element
Acronym
SITE
CNTY
PCDS
PNME
STRT
CYCD
CYNM
ZIPC
SIC1
GOVT
NIC1
SIRS
LCON
PAFS
Data Element
Name
State Code
County Code
Plant ID
Plant Name
Street Address
City Code
City Name
Zip Code
Primary SIC Code
Government
Facility Code
NAICS Code
State Registration
Number
Local Control
Region
AFS ID
Description
A two-character FIPS code identifying the state/territory in
which a plant is located.
A three character FIPS code which identifies the county
in which a plant is located and the county in which the
office or business of the contractor responsible for
asbestos Demo/Reno work is located.
A five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
The name associated with a plant at a given location.
The street address for the physical location of the plant.
Either City Code or City Name is to be entered in.
The zip code for the physical location of the plant
Enter SIC if NAICS is not available. Either NAICS or SIC
is required.
A one character code identifying facilities owned or
operated by a governmental unit.
Enter NAICS if SIC is not available. Either NAICS or SIC
is required.
This could be the ID that is internal to the particular State
or Local Agency
A user-defined 2 character code identifying the local
control region with jurisdiction over a plant
A fifteen-character plant identifier required to enter permit
information for plants. It must be unique within a county
and requires the FIPS State and County Codes to
uniquely identify a plant in AFS. The AFS ID must be
established on the Plant prior to submitting permit
information. Business Rule Guidance - Each AFS Plant
ID Should Be Assigned A Unique Permit ID
Valid Values
The FIPS code entered must exist on the FIPS
code table. Refer to the Ul Cross Reference
tables or the AFS Database for a complete
listing.
The county code must exist on the county / city
table.
This ID is unique within a state county. It may
contain alpha and numeric values.
PO Box is not a valid value
0-all other facilities not owned or operated by a
federal, state, or local government; 1 -source
owned or operated by the federal government;
2-source owned or operated by the state; 3-
source owned or operated by the county; 4-
source owned or operated by the municipality;
5-source owned or operated by the district
Up to 15 alphanumeric characters
2 alphanumeric characters
Up to 15 alphanumeric characters
2 of 13
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AFS Contingency Data Entry Form - Notes
Compliance Enforcement - Air Program Record
This record contains information on the regulatory program of the Clean Air Act that is applicable to a
source
Data Element
Acronym
Data Element
Name
Description
Valid Values
SITE
State Code
a two-character FIPS code identifying the state/territory
in which a plant is located.
The FIPS code entered must exist on the FIPS code table. Refer to
the Ul Cross Reference tables or the AFS Database for a complete
listing.
CNTY
County Code
a three character FIPS code which identifies the county
in which a plant is located and the county in which the
office or business of the contractor responsible for
asbestos Demo/Reno work is located.
The county code must exist on the county / city table.
PCDS
Plant ID
a five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
This ID is unique within a state county. It may contain alpha and
numeric values.
APC1
Air Program Code
a one character alphanumeric code used to identify the
regulatory air program(s) a plant or point is subject to
and the regulatory air program(s) authorizing and
associated with an action taken by a local, state or
federal regulatory agency.
A Acid Precipitation, F - FESOP - (Non-Title V), I - Native
American, M - MACT (Section 63 NESHAPS), V - Title V Permits, 0 -
SIP Source, 1 - SIP Source Under Federal Jurisdiction, 3 - Non-
Federally Reportable Source, 4 - CFC Tracking, 6 - PSD, 7 - NSR, 8
NESHAP, 9 - NSPS
AST1
Air Program Operating
Status
represents the operational condition of a plant
associated with a given air program
O-operating, P- planned (has applied for a construction permit), C-
under construction, T- temporarily closed, X - permanently closed, I -
seasonal, D - NESHAP demolition, R - NESHAP renovation, S -
NESHAP spraying, L - landfill
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
SPT1
CFR Subparts 1 thru
12
Subparts are codes indicating the subpart for air
programs: "9" - NSPS; "8" -NESHAP and; "M" - MACT
NESHAP. The subpart information pertains to sections
60, 61 and 63 of the code of federal regulations
respectively. NSPS Subparts may also be entered on
the SIP air program. Subpart data is required for NSPS,
NESHAPS, and MACT air program codes. Subparts
may be indicated on the SIP air program if applicable.
Up to 12 subpart codes may be associated with each
plant air program.
The Subpart Code must exist on the subparts code table for the
correct air program. Refer to the Ul Cross Reference Tables or the
AFS database for current listing of subparts.
3 of 13
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AFS Contingency Data Entry Form Notes
Compliance Enforcement - Air Program Pollutant Record
This record contains data fields used to describe the pollutants linked to the source under regulation
for a specific air program.
Data Element
Acronym
SITE
CNTY
PCDS
APC1
PLAP
CAPP
SCAP
SCLP
SATT
ECAP
ECLP
EATT
Data Element
Name
State Code
County Code
Plant ID
Air Program Code
Pollutant Code
Chemical Abstract
Service Number
State Pollutant
Compliance Status
State Pollutant
Classification
State Attainment
Indicator
EPA Pollutant
Compliance Status
EPA Pollutant
Classification
EPA Attainment
Monattainment
Indicator
Description
a two-character FIPS code identifying the state/territory
in which a plant is located.
a three character FIPS code which identifies the county
in which a plant is located and the county in which the
office or business of the contractor responsible for
asbestos Demo/Reno work is located.
a five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
a one character code used to identify the regulatory air
program(s) a plant or point is subject to and the
regulatory air program(s) authorizing and associated
with an action taken by a local , state or federal
regulatory agency.
a five character code or up to 9 digit Chemical
Abstract Service Number identifying a pollutant tracked
at the plant level on the pollutant air program (MDR if
criteria). It is a supporting element for actions.
If the pollutant code is not available then the Chemical
Abstract Service Number must be supplied.
a one-character code which reflects the state agency's
determination of the compliance status of a facility with
regards to pollutants regulated by an air program or by
the procedural requirements of a permit. Compliance
falls within four categories: in, out, on schedule, and
unknown. Values entered at the plant air program
pollutant level are compared by AFS, and the most
serious generated and displayed at the plant air
program level. The most serious of the air program
values are in turn displayed at the plant general level.
a two character code assigning a plant classification to
individual criteria pollutants regulated by an air
program. This code may be different than the EPA
pollutant classification.
A one character code identifying the criteria pollutant
attainment status for the county in which the plant is
located. This field is mandatory only for air programs
other than NESHAP and in conjunction with the
following criteria pollutants: VOC, PT, SO2.
a one-character code which reflects the state agency's
determination of the compliance status of a facility with
regards to pollutants regulated by an air program or by
the procedural requirements of a permit. This value is
normally populated only when the EPA assessment
differs from the state. Compliance falls within four
categories: in, out, on schedule, and unknown. Values
entered at the plant air program pollutant level are
compared by AFS, and the most serious generated and
displayed at the plant air program level. The most
serious of the air program values are in turn displayed
at the plant general level.
A one character code identifying the criteria pollutant
attainment status for the county in which the plant is
located. This field is mandatory only for air programs
other than NESHAP and in conjunction with the
following criteria pollutants: VOC, PT, SO2. This field
is used when an EPA classification value differs
from the classification value submitted by a state.
A one character code identifying the criteria pollutant
attainment status for the county in which the plant is
located. This field is mandatory only for air programs
other than NESHAP and in conjunction with the
following criteria pollutants: VOC, PT, SO2. This field
is used when an EPA attainment/non-attainment
indicator value differs from an attainment/non-
attainment indicator value submitted by a state.
Valid Values
The FIPS code entered must exist on the FIPS code table. Refer to the Ul Cross
Reference tables or the AFS Database for a complete listing.
The county code must exist on the county / city table.
This ID is unique within a state county. It may contain alpha and numeric values.
A AHrt PrpHnitatinn F ~ FESOP - (Non-Title V), 1 - Native American, M - MACT
(Section &NESHAPS), V - Title V Permits, 0 -SIP Source, 1 - SIP Source Under
Federal Jurisdiction, 3 - Non-Federally Reportable Source, 4 - CFC Tracking, 6 -
PSD, 7 - NSR, 8 - NESHAP, 9 - NSPS
Either PLAP or CAPP are required. This 5-digit code can be retrieved from the
AFS database, or the Ul Cross Reference Tables
Either PLAP or CAPP are required. This 9-digit code can be taken from the
internet or from the AFS website, or the Ul Cross Reference Tables
\in order from worst to best case ]: Out of compliance: B- in violation with regard
to both emissions and procedural compliance, 1- in violation no schedule, 6 - in
violation-not meeting schedule, W- in violation with regard to procedural
compliance. Unknown compliance: Y - unknown with regard to both emissions
and procedural compliance, 0 - unknown compliance status, A - unknown with
regard to procedural compliance, 7 - in violation - unknown with regard to
schedule. On schedule: 5 - meeting compliance schedule. In compliance: C - in
compliance with procedural requirements, 4- in compliance- certification, 3- in
compliance-inspection, M- in compliance-cems, 2- in compliance-source test, 8-
no applicable state regulation, 9 - in compliance-shut down, P - present, see other
program(s).
A -Major emissions; actual or potential emissions are above the applicable major
source thresholds, SM - Synthetic Minor emissions ; Potential emissions are
Delowall applicable major source thresholds if an only if the sources complies with
Federally enforceable regulations or limitations (Potential to emit at the major
threshold but due to operation restrictions or other controls emit at the minor level),
B - Minor emission ; Potential uncontrolled emissions are below the applicable
major source thresholds, C - Emissions classification is unknown .
A- Attainment area for given pollutant; M- Moderate (for VOC, NO2, CO and
particulate); S- Serious (forVOC, NO2, CO and particulate); V- Severe (for
VOC and NO2); X - Extreme (for VOC and NO2); T- Transport region not serious,
severe, or extreme (VOC only); N - All other non-attainment for primary and
secondary standards; 1 - Non-attainment for primary SO2 standards; 2 -Non-
attainment for secondary PT or SO2 standards; U - Unclassified
\in order from worst to best case ]: Out of compliance: B- in violation with regard
:o both emissions and procedural compliance, 1- in violation no schedule, 6 - in
violation-not meeting schedule, W- in violation with regard to procedural
compliance. Unknown compliance: Y - unknown with regard to both emissions
and procedural compliance, 0 - unknown compliance status, A - unknown with
regard to procedural compliance, 7 - in violation - unknown with regard to
schedule. On schedule: 5 - meeting compliance schedule. In compliance: C - in
compliance with procedural requirements, 4- in compliance- certification, 3- in
compliance-inspection, M- in compliance-cems, 2- in compliance-source test, 8-
no applicable state regulation, 9 - in compliance-shut down, P - present, see other
program(s).
A -Major emissions; actual or potential emissions are above the applicable major
source thresholds, SM - Synthetic Minor emissions ; Potential emissions are
Delowall applicable major source thresholds if an only if the sources complies with
Federally enforceable regulations or limitations (Potential to emit at the major
threshold but due to operation restrictions or other controls emit at the minor level),
B - Minor emission ; Potential uncontrolled emissions are below the applicable
major source thresholds, C - Emissions classification is unknown .
A- Attainment area for given pollutant; M- Moderate (for VOC, NO2, CO and
particulate); S- Serious (for VOC, NO2, CO and particulate); V- Severe (for
VOC and NO2); X - Extreme (for VOC and NO2); T- Transport region not serious,
severe, or extreme (VOC only); N - All other non-attainment for primary and
secondary standards; 1 - Non-attainment for primary SO2 standards; 2 -Non-
attainment for secondary PT or SO2 standards; U - Unclassified
-------
AFS Contingency Data Entry Form -- Notes
Compliance Enforcement - Action Record
record contains fields related to an action a
Data Element
Acronym
SITE
CNTY
PCDS
ANU1
KAN1
ACS1
ACS1
ACS1
ACS1
ACS1
ACS1
APCodel
AP Code 2
AP Code3
AP Code 4
AP Codes
AP Codes
ATP1
DTS1
DTA1
PAM1
RSC1
SCC1
PLC1
CAA1
RD81
R161
LDC1
VID1
VTP1
VTP1
VTP1
VTP1
VTP1
VTP1
VTP1
VPL1
VPL1
VPL1
Type Code 1
TypeCode2
Type Code3
Type Code 4
Type Codes
Type Codes
TypeCodeT
Pollutant 1
Pollutant 2
Pollutants
Data Element
Name
State Code
County Code
Plant ID
Action Number
Key Action Number
Air Program Code
(1 thru 6)
Action Type
Date Scheduled
Date Achieved
Penalty Amount
Results code
Staff Code
Pollutant
CAS Number
RDE8
RDE16
Lead Aqency
Violating Identifier
Violation Type
Code (1 thru 7)
Violating Pollutant
(1 thru 3)
Description
a two-character FIPS code identifying the
state/territory in which a plant is located.
a three character FIPS code which identifies the
county in which a plant is located and the county in
which the office or business of the contractor
responsible for asbestos Demo/Reno work is located.
a five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
A three digit numeric action identifier.
A key action number assigned to an action to indicate
which violation pathway the action is linked. An
action can be linked into a maximum of five pathways.
a one character code used to identify the regulatory
air program(s) a plant or point is subject to and or the
regulatory air program(s) authorizing and associated
with an action taken by a local, state or federal
regulatory agency.
a two character code identifying a compliance activity.
Two categories of action types exist: national action
types, which are used to retrieve similar compliance
activities identified by EPA regions using region-
specific action type codes; and regional action types,
which are the region-specific codes used to identify a
compliance activity
the date on which a compliance action is scheduled to
be performed.
the date on which a compliance action (activity) is
completed
the civil penalty assessed against a facility in the final
agreement between the enforcement authority and the
plant.
an MDR for stack test results. The conclusion of all
stack tests should be recorded using two character
codes indicating "Pass" , "Fail", or "99" for pending. It
is a supporting element for all other actions.
three character code identifying: 1) the compliance or
enforcement official assigned to monitor the
compliance status of a plant, or 2) the staff member
assigned to complete an action.
a five character code or up to 9 digit Chemical
Abstract Service Number identifying a pollutant
tracked at the plant level on the pollutant air program
(MDR if criteria). It is a supporting element for actions.
a five character code or up to 9 digit Chemical
Abstract Service Number identifying a pollutant
tracked at the plant level on the pollutant air program
(MDR if criteria). It is a supporting element for actions.
A field defined by users and used to maintain
information relating to plant or point level actions.
A field defined by users and used to maintain
information relating to plant or point level actions.
a one character code that identifies the agency taking
the lead role in tracking an action linking pathway to
resolution.
a one character code that indicates which agency
identified the violation that requires tracking to
Three character code(s) that identify the types of
violations cited for a violation or administrative
penalty. Violation Type Code(s) may be input for
violations or administrative penalties being tracked
a five character code identifying a pollutant for the air
program which has been identified as being in
violation. This code enables a historical record of
Valid Values
The FIPS code entered must exist on the FIPS code table. Refer to
the Ul Cross Reference tables or the AFS Database for a complete
listing.
The county code must exist on the county / city table.
This ID is unique within a state county. It may contain alpha and
Numeric values between 1 and 999; input values of 999 will
generate the next available sequential action number.
For violation pathways, KAN1 is an MDR. Key action numbers for
an action will be assigned, when requested, to national action type
2E- State Day Zero
AmlncarirefiMAJCt (Section 63 NESHAPS), V - Title V Permits, 0
SIP Source, 1 - SIP Source Under Federal Jurisdiction, 3- Non-
Federally Reportable Source, 4 - CFC Tracking, 6 - PSD, 7 - NSR, 8
-NESHAP, 9- NSPS
The action type code must exist on the AFS list of actions. Refer to
the Ul Cross Reference tables or the AFS database for the listing of
action types by region or national.
DTS1 is a necessary field when entering TV Annual Compliance
Certification due dates.
Date format must be "YYYYMMDD"
0 - 999,999,999 (commas are not entered)
RSC1 is required when entering TV Annual Compliance Certification
The staff code must exist on the staff code table. Please refer to the
Ul cross-reference tables, or the AFS for staff code listings.
Code must exist on the pollutant table
RDO8 Certification Deviations (RD81) EPA reports into AFS unless
otherwise negotiated. Deviations are to be reported by EPA: Y=
Yes, N=No, or a number of Deviations reported may be entered.
Note that compliance status is to be reported in the Results Code
field: MC=in compliance, MV= in Violation, MU = Unknown.
F - FEDERAL; J - JOINT; L - LOCAL; S - STATE
F - FEDERAL; J - JOINT; L - LOCAL; S - STATE
Code entered must exist on table. Refer to the Ul Cross Reference
Tables for the listing of applicable violation type codes.
Code must exist on the pollutant table. Refer to the Ul Cross
Reference Tables for the listing of applicable pollutant codes.
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AFS Contingency Data Entry Form - Notes
Permit - Permit Record
The following fields are necessary for a complete permit draft record; SITE, ASPN, PMTC & PAFS.
Data Element
Acronym
SITE
ASPN
PMTC
PMFD
ASRD
PMXD
AAD1
CNTY
PAFS
Data Element
Name
State code
Permit ID
Category
Effective Date
Mod/Renewal
Effective Date
Expiration Date
(Projected)
Permitting Authority
Data Element
County
AFS ID
Description
a two-character FIPS code identifying the state/territory in
which a plant is located.
User defined value to identify a permit. The combination of
State and Permit ID uniquely identifies a permit.
A code that indicates the kind of Permit. Title V and Non-Title
V Permits are both supported.
The date a permit takes effect.
The date the last modification or renewal to a permit takes
effect.
The projected date a permit is scheduled to expire and would
no longer be in effect. Note: Submit a Permit Expires Event
to reflect an Actual Permit Expiration Date where the permit
has expired and is no longer in effect.
Optional User-defined field provided for agency
representatives to maintain permit information that relates to
a permit or application.
a three character FIPS code which identifies the county in
which a plant is located and the county in which the office or
business of the contractor responsible for asbestos
Demo/Reno work is located.
A fifteen-character plant identifier required to enter permit
information for plants. It must be unique within a county and
requires the FIPS State and County Codes to uniquely
identify a plant in AFS. The AFS ID must be established on
the Plant prior to submitting permit information. Business
Rule Guidance - Each AFS Plant ID Should Be Assigned A
Unique Permit ID
Valid Values
The FIPS code entered must exist on the FIPS code table. Refer to the Ul
Cross Reference tables or the AFS Database for a complete listing.
C - NON-TITLE V PERMIT - PERMIT TO CONSTRUCT; G - TITLE V
PERMIT - GENERAL PERMIT; N - NON-TITLE V PERMIT - OPERATING
PERMIT; V - TITLE V PERMIT - PLANT SPECIFIC
Date Format: YYYYMMDD
Date Format: YYYYMMDD
Date Format: YYYYMMDD
The county code must exist on the county / city table.
6 of 13
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AFS Contingency Data Entry Form - Notes
Permit - Permit Event Record
To ensure a full and complete permit event record ALL the fields in the table are necessary.
Please fill out completely.
Data Element
Acronym
SITE
CNTY
PAFS
PAPN
PATY
PACN
PDEA
PARC
Data Element
Name
State Code
County Code
AFS ID
Permit ID
Event Type
Event Number
Date Achieved
Results
Description
a two-character FIPS code identifying the
state/territory in which a plant is located.
a three character FIPS code which identifies the
county in which a plant is located and the county in
which the office or business of the contractor
responsible for asbestos Demo/Reno work is located.
A fifteen-character plant identifier required to enter
permit information for plants. It must be unique within a
county and requires the FIPS State and County Codes
to uniquely identify a plant in AFS. The AFS ID must
be established on the Plant prior to submitting permit
information. Business Rule Guidance - Each AFS
Plant ID Should Be Assigned A Unique Permit ID
User defined value to identify a permit. The
combination of State and Permit ID uniquely identifies
a permit.
A code identifying a permitting related activity. Once
the permit is issued, these events can not be deleted
from the data base (unless the entire permit is
deleted).
A user defined number to identify permit event. Users
may enter '999' to have AFS assign the next available
number. The combination of State, County, AFS Plant
ID, Permit Event Type and Permit Event Number
uniquely identifies an event in AFS.
The date on which a permit event is completed. Title V
and Non-Title V Permits are both supported.
A two-character code indicating whether an event has
been achieved or if another event should be referred
to.
Valid Values
The FIPS code entered must exist on the FIPS code table. Refer to
the Ul Cross Reference tables or the AFS Database for a complete
listing.
The county code must exist on the county / city table.
Refer to the Ul Cross Reference tables or the AFS database for the
complete listing. Mandatory Events in the Ul table
Integer values between 001 - 999
yyyymmdd - Either Date Scheduled or Date Achieved is required
Must exist on the Ul table
7 of 13
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AFS Contingency Data Entry Form - Notes
Continuous Emissions Monitoring - Point General Record
Data Element
Acronym
SITE
CNTY
PCDS
PNUM
CEID
DSC3
Data Element
Name
State code
County Code
Plant ID
Point ID
Point C/E ID
Point Description
Description
a two-character FIPS code identifying the
state/territory in which a plant is located.
a three character FIPS code which identifies the
county in which a plant is located and the county in
which the office or business of the contractor
responsible for asbestos Demo/Reno work is located.
a five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
A three-character field used to identify a point
A one-character field used to distinguish emission
point numbers from compliance point numbers and
identify Merged points.
A description of a point monitored for compliance.
Valid Values
The FIPS code entered must exist on the FIPS code table.
Refer to the Ul Cross Reference tables or the AFS Database
fora complete listing.
The county code must exist on the county / city table.
This ID is unique within a state county. It may contain alpha
and numeric values.
Must be 3 alphanumeric characters
C - Compliance; M - Merged; System-generated ("C")
when adding a point to a compliance-only facility. User
supplied value required when adding a point to a merged
facility.
Up to 25 alphanumeric characters
8 of 13
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AFS Contingency Data Entry Form Notes
Continuous Emissions Monitoring - Point Air Program Record
The following fields are necessary for a complete point air program record; STTE, CNTY, PCDS, PNUM,
CEID, APC3, SCA3 & AST3. Please fill out completely.
Data Element
Acronym
STTE
CNTY
PCDS
PNUM
CEID
APC3
SPT3 1 SubPart 1
SPT3 | SubPart 12
SCA3
AST3
Data Element Name
State Code
County Code
Plant ID
Point ID
Point C/E ID
Point Air Program
Point Level Sub Part (1 thru 12)
Point Compliance Status
Point Operating Status
Description
a two-character FIPS code identifying the
state/territory in which a plant is located.
a three character FIPS code which identifies the
county in which a plant is located and the county
in which the office or business of the contractor
responsible for asbestos Demo/Reno work is
located.
a five character plant identifier required to assign
compliance information to plants in the AIRS
facility subsystem. Formerly called CDS Plant ID.
A three-character field used to identify a point
A one-character field used to distinguish
emission point numbers from compliance point
numbers and identify Merged points.
A one character code used to identify the
regulatory air program(s) Point is subject to.
Subparts are codes indicating the subpart for air
programs: "9" - NSPS; "8" -NESHAP and; "M" -
MACT NESHAP. The subpart information
pertains to sections 60, 61 and 63 of the code of
federal regulations respectively. NSPS Subparts
may also be entered on the SIP air program.
Subpart data is required for NSPS, NESHAPS,
and MACT air program codes. Subparts may
be indicated on the SIP air program if applicable.
Up to 12 subpart codes may be associated with
each plant air program.
A one-character code which reflects the state
agency's determination of the compliance status
of a facility with regards to pollutants regulated
by an air program or by the procedural
requirements of a permit. Compliance falls
within four categories: in, out, on schedule, and
unknown. Values entered at the point air
program pollutant level are NOT bubbled up to
the plant level.
Represents the operational condition of a point
associated with a given air program.
Valid Values
The FIPS code entered must exist on the FIPS code table.
Refer to the Ul Cross Reference tables or the AFS
Database for a complete listing.
The county code must exist on the county / city table.
This ID is unique within a state county. It may contain
alpha and numeric values.
Must be 3 alphanumeric characters
C- Compliance; M- Merged; System-generated ("C")
when adding a point to a compliance-only facility. User
supplied value required when adding a point to a merged
facility.
A - ACID PRECIPITATION; F - FESOP - (Non-Title V); I -
NATIVE AMERICAN; M - MACT (SECTION 63
NESHAPS); V - TITLE V PERMITS
0 - SIP SOURCE; 1 - SIP SOURCE UNDER FEDERAL
JURISDICTION; 3 - NON-FEDERALLY REPORTABLE
SOURCE; 4 - CFC TRACKING
6 - PSD; 7 - NSR; 8 - NESHAP; 9 - NSPS
The Subpart Code must exist on the subparts code table
for the correct air program. Refer to the Ul Cross
Reference Tables or the AFS database for current listing
of subparts.
" operating' ^ planned (has applied for a construction
" '' under construction; temporarily closed;
permanentfy closed; T D NFqHAP
Hemnlitinn- R seasonal; WtbHAK
demolition, R NEงHAP renovation; S NESHAP
spraying; L- landfill
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AFS Contingency Data Entry Form -- Notes
Continuous Emission Monitoring - Monitor Record
The following fields are necessary for a complete monitor record; SITE, CNTY, PCDS, PNUM,
CEID, &CHNM, as they are used to identify the equipment. In addition please enter information
for at least ONE of the following fields to provide descriptive information about the equipment:
MTMR, MTMN, MTSN, MTRC, CEMA, PEML, MTID, PSTD, PSTS &/or CEDT.
Data Element
Acronym
SITE
CNTY
PCDS
PNUM
CEID
CHNM
MTMR
MTMN
MTSN
MTRC
CEMA
PEML
MTID
PSTD
PSTS
CEDT
Data Element
Name
State Code
County Code
Plant ID
Point ID
Point C/E ID
Channel Number
Manufacturer
Model Number
Serial Number
Requirement Code
Enforcement Agency
Permissible Limit
Installation Date
Performance Specifica
Performance Specifica
Certification Date
Description
a two-character FIPS code identifying the
state/territory in which a plant is located.
a three character FIPS code which identifies the
county in which a plant is located and the county in
which the office or business of the contractor
responsible for asbestos Demo/Reno work is
located.
a five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
A three-character field used to identify a point
A one-character field used to distinguish emission
point numbers from compliance point numbers and
identify Merged points.
A three-character code identifying the channel
number associated with a point monitor.
The manufacturer of the primary component of the
monitoring unit.
The monitor primary component model number.
The serial number used to identify a primary
component monitoring unit.
A one-character code identifying the air program
regulation, enforcement action, compliance order, or
consent decree requiring the installation of
Continuous Emissions Monitoring equipment.
A one character code identifying the federal, state
or local agency with enforcement jurisdiction for
Continuous Emission Monitoring at the plant.
The emission value and units specified by the
monitor regulation emission value and units.
The year and month in which the monitor was
installed.
The year and month that the latest performance
specification test was performed.
The result of the latest performance specification
test.
The date the continuous emissions monitor received
certification.
Valid Values
The FIPS code entered must exist on the FIPS code table. Refer to the Ul
Cross Reference tables or the AFS Database for a complete listing.
The county code must exist on the county / city table.
This ID is unique within a state county. It may contain alpha and numeric
values.
Must be 3 alphanumeric characters
C - Compliance; M - Merged; System-generated ("C") when adding a point
to a compliance-only facility. User supplied value required when adding a
point to a merged facility.
First character- parameter beina monitored: 0 - Air toxics monitor: 1 -
Opacity monitor; 2 - Sulfur dioxide (so2) monitor; 3 - NOx monitor; 4 -
Diluent (oxygen or carbon dioxide) monitor; 5 - Hydrocarbon; 6 - Total
reduced sulfur (so2) monitor; 7 - Hydrogen disulfide monitor; 8 - Carbon
monoxide; 9 - Coal sampling and analysis. Second character - monitor
indicator: To indicate that the channel number is associated with a point
monitor, the second position must equal "1". Third character: Single/group
monitor number indicates if a monitor is the single monitor for the point or
one of several monitoring the point; Single monitors are indicated by a
value of "1"; Cluster monitors are indicated by a sequential number
between 2-9.
Up to 20 alphanumeric characters.
Up to 15 alphanumeric characters.
Up To 15 Alphanumeric Characters.
A - Acid rain precipitation; 0 - SIP Source; 1 - No Federal Requirement; 3 -
Enforcement action, compliance order or consent decree; 6 - PSD; 9 -
NSPS
1 - EPA-Headquarters; 2 - EPA-Region; 3 - State; 4 - Local
Up to 20 alphanumeric characters.
Date format YYYYMM
Date format YYYYMM
Pass; Fail
Date format YYYYMMDD
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AFS Contingency Data Entry Form -- Notes
Continuous Emissions Monitor - Excess Emission Report Record
The following fields are necessary for a complete excess emission report record; SITE, CNTY, PCDS, PNUM, CEID,
CHNE & RQT3. In addition please enter information for at least ONE of the following fields to provide descriptive
information about the emission; ACSP, TSOT, TIMC, STSH, CLSB, UNEE, CLEF, CLMU, PPRO, PPRU, INEE, FUPB,
OKEE, MTEM, MNEM, CALB, UNMD, OKMD &/or INMD.
Data Element
Acronym
SITE
CNTY
PCDS
PNUM
CEID
CHNE
YEAR
RQT3 OTR
ACSP EERAIRPRGM1
ACSP EERAIRPRGM2
ACSP EERAIRPRGM3
ACSP EERAIRPRGM4
ACSP EERAIRPRGM5
ACSP EERAIRPRGM6
TSOT
TIMC
STSH
CLSB
UNEE
CLEF
CLMU
PPRO
PPRU
INEE
FUPB
OKEE
MTEM
MNEM
CALB
UNMD
OKMD
INMD
Data Element Name
State Code
County Code
Plant ID
Point ID
Point C/E ID
Channel Number
Report Quarter
EERAir Program (1 thru 16)
Total Source Operating Time
Time Period Code
Start-up /Shut-down
Cleaning / Soot-blowinq
Unknown Excess
Control Equipment Failure
Control Equipment Malfunction
Unacceptable
Process Problems
Process Problems
Unacceptable
Number of Incidents of Excess
Emissions
Fuel Problems
Other Known Excessess
Monitor Equipment Malfunction
''Jon-Monitor Equipment
Malfunction
Calibration
Unknown Monitor Downtime
Other Known Monitor Downtime
Number of Incidents of Monitor
Downtime
Description
a two-character FIPS code identifying the state/territory in
which a plant is located.
a three character FIPS code which identifies the county in
which a plant is located and the county in which the office or
Dusiness of the contractor responsible for asbestos
Demo/Reno work is located.
a five character plant identifier required to assign compliance
nformation to plants in the AIRS facility subsystem. Formerly
called CDS Plant ID.
A three-character field used to identify a point
A one-character field used to distinguish emission point
numbers from compliance point numbers and identify Merged
points.
A three-character code identifying the channel number
associated with a point monitor.
Identifies the year and quarter in which a Continuous
Emissions Monitoring Excess Emissions Report was
A one character code used to identify the regulatory air
program(s) that is the reason an EER is produced.
The total amount of time a plant is operating during the
specified report quarter.
A one-character code indicating the units of time applied to
quarterly excess emissions reported in an excess emissions
report.
A count of the quarterly excess emissions period units
associated with the starting up or shutting down of the source.
Count of the number of excess emission time periods due to
cleaning/soot blowing, during the reporting quarter.
The total number of quarterly excess emissions periods/units
Sum of quarterly excess emission period units due to
unit/control equipment failure or malfunction.
Sum of quarterly excess emission period units due to control
equipment malfunctions that were deemed unacceptable.
Jsed only if the control equipment malfunctions are a large
oortion of the total excess emissions, and a breakdown
Between acceptable malfunctions and any unacceptable
malfunctions is deemed necessary. Guidance on the use of
this field is available from each EPA Regional Continuous
Emissions Monitoring coordinator.
The summary total of quarterly excess emission period/units
due to acceptable and unacceptable process problems defined
ay the monitorinq aqency.
Sum of quarterly excess emission reporting period units due to
process problems that were deemed unacceptable, as defined
ay the monitoring agency.
Total number of quarterly incidents of excess emissions
recorded by a monitor.
The number of quarterly period units the monitor recorded
excess emissions due to fuel problems.
The number of period units during the quarter the monitor
recorded excess emissions due to other known reasons.
The number of quarterly monitor downtime period units due to
:he malfunction of the monitor equipment.
The number of quarterly monitor downtime period units due to
the malfunction of non-monitor equipment.
The number of quarterly time period units the source was
operating and the monitor was not operating due to monitor
calibration.
The number of quarterly monitor down time period/units due to
unknown reasons.
The number of monitor downtime period units during the
quarter due to other known reasons.
The total number of quarterly incidents of monitor downtime.
Valid Values
The FIPS code entered must exist on the FIPS code table. Refer to the Ul
Cross Reference tables or the AFS Database for a complete listing.
The county code must exist on the county / city table.
This ID is unique within a state county. It may contain alpha and numeric
Must be 3 alphanumeric characters
C - Compliance; M - Merged; System-generated ("C") when adding a point
to a compliance-only facility. User supplied value required when adding a
point to a merged facility.
First character- oarameter beinq monitored : 0 - Air toxics monitor: 1 -
Opacity monitor; 2 - Sulfur dioxide fso2) monitor; 3 - NOx monitor; 4 - Diluent
(oxygen or carbon dioxide) monitor; 5 - Hydrocarbon; 6 - Total reduced sulfur
(so2) monitor; 7 - Hydrogen disulfide monitor; 8 - Carbon monoxide; 9 - Coal
sampling and analysis. Second character - monitor indicator: To indicate
that the channel number is associated with a point monitor, the second
position must equal "1". Third character: Single/group monitor number
indicates if a monitor is the single monitor for the point or one of several
monitoring the point; Single monitors are indicated by a value of "1 "; Cluster
monitors are indicated by a sequential number between 2-9.
Date format YYYYQQ; Where QQ represents quarter values of 01, 02, 03, 04
A -ACID PRECIPITATION; 1- NATIVE AMERICAN; M - MACT (SECTION 63
NESHAPS); V- TITLE V PERMITS; 0- SIP SOURCE; 1 - SIP; SOURCE
UNDER FEDERAL JURISDICTION; 3- NON-FEDERALLY REPORTABLE
SOURCE; 4- CFC TRACKING; 6- PSD; 7- NSR; 8 - NESHAP; 9 - NSPS
0 - 999,999
M - Minutes; A - 6 Minutes; B - 1 5 Minutes; C - 30 Minutes; D - 1 Hour (60
Minutes); E - 2 Hours (120 Minutes)
0 - 999,999
0 - 999,999
0 - 999,999
0 - 999,999
0 - 999,999
0 - 999,999
0 - 999,999
0-999
0 - 999,999
0 - 999,999
0 - 999,999
0 - 999,999
1 - 999,999
0 - 999999
0 - 999,999
0-999
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AFS Contingency Data Entry Form - Notes
Compliance Monitoring Strategy - CMS Record
This record captures information related to compliance monitoring activities.
Data Element
Acronym
SITE
CNTY
PCDS
CMSC
CMSI
CMYA
CMOA
CMYB
CMOB
CMYC
CMOC
CMYD
CMOD
CMYE
CMOE
CM19
Data Element Name
State Code
County Code
Plant ID
Source Category
CMS Min Frequency Indicator
Fiscal Year of FCE A
On Site Visit Indicator A
Fiscal Year of FCE B
On Site Visit Indicator B
Fiscal Year of FCE C
On Site Visit Indicator C
Fiscal Year of FCE D
On Site Visit Indicator D
Fiscal Year of FCE E
On Site Visit Indicator E
CMS Comment
Description
a two-character FIPS code identifying the
state/territory in which a plant is located.
a three character FIPS code which identifies the
county in which a plant is located and the
county in which the office or business of the
contractor responsible for asbestos
Demo/Reno work is located.
a five character plant identifier required to
assign compliance information to plants in the
AIRS facility subsystem. Formerly called CDS
Plant ID.
A one character code that indicates the source
category to which a facility subject to CMS
belongs.
A one digit field indicating the number of years
allowable between full compliance evaluations.
A four digit year indicating the year that a full
compliance evaluation has been scheduled as
defined in the CMS plan. There are 5
occurrences.
A 1 character flag indicating if an on-site visit is
planned for a given fiscal year. Default value is
'Y'. There are 5 occurrences.
A four digit year indicating the year that a full
compliance evaluation has been scheduled as
defined in the CMS plan. There are 5
occurrences.
A 1 character flag indicating if an on-site visit is
planned for a given fiscal year. Default value is
'Y'. There are 5 occurrences.
A four digit year indicating the year that a full
compliance evaluation has been scheduled as
defined in the CMS plan. There are 5
occurrences.
A 1 character flag indicating if an on-site visit is
planned for a given fiscal year. Default value is
'Y'. There are 5 occurrences.
A four digit year indicating the year that a full
compliance evaluation has been scheduled as
defined in the CMS plan. There are 5
occurrences.
A 1 character flag indicating if an on-site visit is
planned for a given fiscal year. Default value is
'Y'. There are 5 occurrences.
A four digit year indicating the year that a full
compliance evaluation has been scheduled as
defined in the CMS plan. There are 5
occurrences.
A 1 character flag indicating if an on-site visit is
planned for a given fiscal year. Default value is
'Y'. There are 5 occurrences.
an optional field which permits the user to enter
additional information for the plant CMS record.
Comments consist of one lines, which can hold
39 characters.
Valid Values
The FIPS code entered must exist on the
FIPS code table. Refer to the Ul Cross
Reference tables or the AFS Database for
a complete listing.
The county code must exist on the county /
city table.
This ID is unique within a state county. It
may contain alpha and numeric values.
A yjt|e v Major' ฎ ^0% Synthetic Minor; M
Mega-Site; O Other
1 -9
Valid Year >= 2002
Y - An On-site visit is planned; N - An On-
site visit is Not planned
Valid Year >= 2002
Y - An On-site visit is planned; N - An On-
site visit is Not planned
Valid Year >= 2002
Y - An On-site visit is planned; N - An On-
site visit is Not planned
Valid Year >= 2002
Y - An On-site visit is planned; N - An On-
site visit is Not planned
Valid Year >= 2002
Y - An On-site visit is planned; N - An On-
site visit is Not planned
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AFS Contingency Data Entry Form - Notes
Comment Record
If the comment is against the whole plant then an action # is NOT needed. However, if
the comment is for a specific action, then all fields are necessary.
Data
Element
Acronym
SITE
CNTY
PCDS
ANU1
CNU1
COM1
Data Element
Name
State Code
County Code
Plant ID
Action Number
Comment Number
Comment
Description
a two-character FIPS code identifying the state/territory
in which a plant is located.
a three character FIPS code which identifies the county
in which a plant is located and the county in which the
office or business of the contractor responsible for
asbestos Demo/Reno work is located.
a five character plant identifier required to assign
compliance information to plants in the AIRS facility
subsystem. Formerly called CDS Plant ID.
A three digit numeric action identifier.
a three-digit numeric comment identifier.
an optional field which permits the user to enter
additional information for an action. Comments consist
of four lines, each of which can hold 55, 57, 57 and 57
characters respectively.
Valid Values
The FIPS code entered must exist on the
FIPS code table. Refer to the Ul Cross
Reference tables or the AFS Database for a
complete listing.
The county code must exist on the county /
city table.
This ID is unique within a state county. It
may contain alpha and numeric values.
Numeric values between 1 and 999; input
values of 999 will generate the next
available sequential action number.
0 - 999; input values of 999 will generate the
next available sequential action comment
number.
13of13
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TABLE 1
SUMMARY OF NATIONAL MINIMUM DATA REQUIREMENTS (MDRs)
FOR CLEAN AIR ACT STATIONARY SOURCE COMPLIANCE
Note: Unless otherwise noted, both Regions and states/locals report their data. The reportable universe
of facilities for AFS includes: Major, Synthetic Minor and Part 61 NESHAP Minor facilities, other
facilities identified within the CMS Evaluation Plan, any facility with a formal enforcement action and
any facility with an active HPV. Facilities with formal enforcement actions (administrative orders,
consent decrees, civil or criminal referrals and actions) should be tracked in AFS until the resolution of
the violation, regardless of classification. If a minor source is included in the CMS universe, has a current
enforcement action of <3 years old, or is listed as a discretionary HPV, it is considered reportable to AFS.
Individual regional/state agreements are not superseded by this listing.
AFS
Identification Acronym
1. Facility Name PNME
2. State STAB/STTE
3. County CNTY
4. Facility Number PCDS
5. Street SIRS
6. City CYNM
7. Zip Code ZIPC
8. SICorNAICSCode SIC I/NIC 1
9. Government Ownership GOVT
10. HPV Linkage and Key Action (Day Zero) Linked from Action Data
Compliance Monitoring Strategy (CMS)
11. CMS Source Category CMSC
12. CMS Minimum Frequency Indicator CMSI
Note: Generally EPA enters these fields into AFS; state/locals provide this information per agreement
with the EPA Region. An EPA Region may delegate data entry rights to a state/local agency.
All Regulated Air Program(s) [Note: All applicable air programs should be reflected at the plant
level of AFS.1
13. Air Program APC1
14. Operating Status AST1
15. Subparts for NSPS, NESHAP and MACT SPT1
Note: Any applicable subpart for the NSPS, NESHAP or MACT air program at major and synthetic
minor sources, minor source NESHAP and all other facilities reported as MDR. Reporting of minor
source NSPS and MACT subparts are optional but recommended.
Regulated Pollutant(s) within Air Program(s)
16. Pollutant(s) by Code or Chemical Abstract Service Number PLAP/CAPP
17. Classification(s): EPA/ST ECLP/SCLP
18. Attainment Status: EPA/ST EATN/SATN
19. Compliance Status: EPA/ST ECAP/SCAP
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Actions Within Air Programs (includes Action Number, Type, Date Achieved)
20. Minimum Reportable Actions:
Informal Enforcement Actions: Notice of Violation(s)
Formal Enforcement Actions: Administrative Order(s) and Assessed Penalties, Consent Decrees
and Agreements, Civil and Criminal Referrals, Civil and Criminal Actions
HPV Violation Discovered: Linked actions are FCEs, PCEs, Stack Tests (Observed or
Reviewed), Title V Annual Compliance Certifications, Stack Test Notification Receipt
HPV Addressing Actions: Linked actions include but are not limited to State/EPA Civil or
Criminal Referrals, State/EPA Civil or Criminal Actions, Administrative Orders, Consent
Decrees, Source Returned to Compliance by State/EPA with no Further Action Required.
FIPV Resolving Actions: Linked actions include but are not limited to Violation Resolved,
Closeout Memo Issued, Source Returned to Compliance by State/EPA with no Further Action
Required.
Full Compliance Evaluations (On or Off Site)
Stack Tests: Pass/Fail/Pending codes (PP/FF/99) are reported in the results code field, pending
codes must be updated within 120 days.
Title V Annual Compliance Certification Due/Received: Reported by EPA unless otherwise
negotiated. The Due Date of a Title V Annual Compliance Certification will be reported as Date
Scheduled on the "Title V Annual Compliance Certification Due/Received by EPA" action, and is
not enforcement sensitive.
Title V Annual Compliance Certification Reviewed: Includes Results Codes for Annual
Compliance Certification reviews: in compliance (MC), in violation (MV) and unknown (MU).
Annual Compliance Certification deviations(s) will be indicated in RD08 for EPA reviews (and
state reviews as negotiated).
Investigations: EPA Investigation Initiated (started) and State/EPA Investigation Conducted
(finished). State Investigation Initiated is added for optional use. EPA and State Investigation
Initiated (started) action types are enforcement sensitive.
Additional Action Information:
21. Results Code RSC1
Note: Pass/Fail/Pending (PP/FF/99) codes are reported for Stack Test actions. Compliance Results
Codes of "In Compliance (MC), In Violation (MV), or Unknown (MU)" are entered for Title V Annual
Compliance Certification reviews.
22. RD08 (Certification Deviations) RD81
Note: EPA reports into AFS unless otherwise negotiated. Compliance Codes of "In Compliance (MC),
In Violation (MV), or Unknown (MU)" are entered for Title V Annual Compliance Certification reviews.
23. Date Scheduled DTS1
Note: The Due Date of a Title V Annual Compliance Certification will be reported as Date Scheduled on
the "Title V Annual Compliance Certification Due/Received by EPA" action, and is not enforcement
sensitive.
24. HPV Violation Type Code(s) VTP1
Note: To be identified when the Day Zero action is established.
25. HPV Violating Pollutant(s) VPL1
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Note: To be identified when the Day Zero action is established.
Timeliness Standard
26. Action Reported within 60 Days of Event reported in the Date Achieved (DTA1) field of the action
record for state and local agencies, with a minimum upload of six (6) times per year. Monthly updating is
encouraged. Federal Data is to be reported on a monthly basis.
OPTIONAL/DISCRETIONARY DATA REPORTING TO AFS: NON-MDR DATA
The following items cover data that is not considered an MDR, but will be useful and helpful for program
implementation, evaluation and oversight. State and local agencies are encouraged to report the
following items whenever practicable.
Minor Facility information: For minor sources that are not MDR (MDR for minor facilities is
defined as: Minor NESHAP, a minor facility identified within the CMS plan for evaluation, minor
facilities with an enforcement action <3 years old, or any HPV case regardless of class) reporting
is optional but encouraged. Minor source information would include NSPS and MACT subpart
applicability.
Stack Test Pollutant (PLC1)
Partial Compliance Evaluations (PCEs) and specific reporting of On-Site PCE activity defined as:
Complaint Partial Compliance Evaluation, Permit Partial Compliance Evaluation, Process Partial
Compliance Evaluation, Partial Compliance Evaluation On-Site Observation. (Note: All PCEs are
required to be reported by EPA Regional offices. Also, any negotiated PCEs that are part of an
alternative frequency which is part of an agency's CMS plan are required to be reported.)
Reporting more frequently than every 60 days.
State Investigations initiated (Enforcement Sensitive).
Title V Permit Program Data Elements (PPDEs): Required for reporting to AFS by the Office of
Air Quality Planning and Standards (OAQPS), used by the Office of Enforcement and
Compliance Assurance (OECA) for major source universe population. To be established when the
Title V permit is issued. AFS will require the establishment of an AFS ID, the individual permit
number, category, and event type for permit issued plus the date achieved. Permit Program Data
Elements (PPDEs) include the Permit Number (ASPN), Permit Category (PMTC), and Permit
Issuance Event Types (IF-Permit Issued and IR-Permit Renewal) and the date (PATY/PDEA).
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