State Review Framework (SRF)
Definitions of the Status of Identified Recommendations
March 2010
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (MC 2221-A)
Washington, D.C. 20460
http://www.epa.gov/compliance/state/srf/index.html
To see a list of acronyms related to SRF: http://www.epa.gov/glossary/aaad.html

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Round 2 Elements
Element 1: Data Completeness. Degree to which the Minimum Data Requirements are complete.
Element 2: Data Accuracy. Degree to which the Minimum Data Requirements are accurate (example,
correct codes used, dates are correct, etc.).
Element 3: Timeliness of Data Entry. Degree to which the Minimum Data Requirements are timely.
Element 4: Completion of Commitments. Degree to which all enforcement/compliance commitments in
relevant agreements (i.e., PPAs, PPGs, categorical grants, CMS plans, authorization agreements, etc.) are
met and any products or projects are completed.
Element 5: Inspection Coverage. Degree to which state completed the universe of planned
inspections/compliance evaluations (addressing core requirements and federal, state and regional
priorities).
Element 6: Quality of Inspection or Compliance Evaluation Reports. Degree to which inspection or
compliance evaluation reports properly document observations, are completed in a timely manner, and
include accurate description of observations.
Element 7: Identification of Alleged Violations. Degree to which compliance determinations are
accurately made and promptly reported in the national database based upon compliance monitoring report
observations and other compliance monitoring information (e.g., facility-reported information).
Element 8: Identification of SNC and HPV. Degree to which the state accurately identifies significant
noncompliance/high priority violations and enters information into the national system in a timely
manner.
Element 9: Enforcement Actions Promote Return to Compliance. Degree to which state enforcement
actions include required corrective action (i.e., injunctive relief or other complying actions) that will
return facilities to compliance in a specific time frame.
Element 10: Timely and Appropriate Action. Degree to which a state takes timely and appropriate
enforcement actions in accordance with policy relating to specific media.
Element 11: Penalty Calculation Method. Degree to which state documents in its files that initial
penalty calculation includes both gravity and economic benefit calculations, appropriately using the BEN
model or other method that produces results consistent with national policy.
Element 12: Final Penalty Assessment and Collection. Degree to which differences between initial and
final penalty are documented in the file along with a demonstration in the file that the final penalty was
collected.
Element 13: Optional element can include compliance assistance, pollution prevention, innovation, self-
disclosure programs, outcome measures, etc. to educate EPA about the scope of a state's program; or can
be used to request recognition or resource flexibility credit when a state runs a satisfactory program.

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Findings
A finding is an observation of activities, processes, or policies that the metrics and/or the file reviews
show are being implemented by the state that have significant problems that need to be addressed and
that require follow-up EPA oversight.
Good Practices: This describes activities, processes, or policies that the SRF data metrics and/or the
file reviews show are being implemented exceptionally well and which the State is expected to
maintain at a high level of performance. Additionally, the report may single out specific innovative
and noteworthy activities, process, or policies that have the potential to be replicated by other States
and that can be highlighted as a practice for other states to emulate. No further action is required by
either EPA or the State.
Meets SRP Program Requirements: This indicates that no issues were identified under this
Element.
Areas for State Attention: This describes activities, processes, or policies that the SRF data metrics
and/or the file reviews show are being implemented with minor deficiencies that the State needs to
pay attention to strengthen its performance, but are not significant enough to require the region to
identify and track state actions to correct. This can describe a situation where a State is implementing
either EPA or State policy in a manner that requires self-correction to resolve concerns identified
during the review. These are single or infrequent instances that do not constitute a pattern of
deficiencies or a significant problem. These are minor issues that the State should self-correct
without additional EPA oversight. However, the State is expected to improve and maintain a high
level of performance.
Areas for State Improvement (Recommendation Required): This describes activities, processes,
or policies that the metrics and/or the file reviews show are being implemented by the state that have
significant problems that need to be addressed and that require follow-up EPA oversight. This can
describe a situation where a state is implementing either EPA or State policy in a manner requiring
EPA attention. For example, these would be areas where the metrics indicate that the State is not
meeting its commitments, there is a pattern of incorrect implementation in updating compliance
data in the data systems, there are incomplete or incorrect inspection reports, and/or there is
ineffective enforcement response. These would be significant issues and not merely random
occurrences. Recommendations are required for these problems that will have well defined timelines
and milestones for completion. Recommendations will be monitored in the SRF Tracker.
Status
Working: The recommendation is in progress, it is expected to be completed, and it is on schedule to
meet agreed upon completion date
Completed: The terms of recommendation have been implemented, the corrections have been agreed
upon, and the work attributed to the recommendation was completed
Being Negotiated: The region and the state still have to determine the timeline and the procedures
for implementing the recommendation, the timeline of recommendation cannot be determined by the
completion of the final report
Long Term Resolution: The recommendation cannot be completed without legislative fix, policy
change, or institutional arrangement that would have to go on to the future
Responsible Agency: The agency that administers the program. Mostly States, but is EPA where
EPA directly implements the program.

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