RCRAInfo Data Appendix for the 2003 ERP
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
Office of Compliance
Washington, DC 20460
March 2005
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Appendix A: RCRAInfo Data Appendix for the 2003 ERP
This appendix is designed to translate the information contained in the December 2003 Enforcement Response Policy (ERP)
into specific RCRAInfo data terms to ensure data is entered into the system correctly in order to accurately reflect the enforcement
program as specified in the attached ERP.
Note: The RCRAInfo data element name and table name are listed in italics.
This Data Appendix will be revised and reissued when RCRAInfo Version 3 changes have been implemented. (With the
release of Version 3, the following new fields will become available for data entry: Day Zero, and the "Addressed SNC Dated"
for enforcement actions. These two new fields will be enforcement sensitive. The proposed date for the release of RCRAInfo
Version 3 is August 2005.)
Definition of terms:
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Implementing
Agency
Implementing Agency is the agency undertaking
the required enforcement response. (Page 8: F)
Implementing agency is agency located in the
cevaluation table, responsible agency located in the
cviolation table, and agency located in the
cenforcement table.
Formal Enforcement
Formal Enforcement is a written document that
mandates compliance and/or initiates a civil or
administrative process, with or without appeal
rights before a trier of fact, that results in (1) an
enforceable agreement or order and (2) an
appropriate sanction. (Page 8: E)
For EPA, formal enforcement action is (1) a
referral to the U.S. Department of Justice for the
commencement of a civil action in the
Formal Enforcement is values 200 - 899 in
fk lu enforcemeenforcement typ located in the
cenforcement table.
For addressing SNC: ONLY the f ollowing formal
actions will be used: 200 - 219, 250 - 259, 300 - 319,
350 - 359, 380, 400 - 519, 530 - 539, 560 - 589, and
600 - 699, and 800 - 899 in
fk lu enforcemeenforcement typ located in the
cenforcement table.
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appropriate U.S. District Court, or (2) the filing of
an administrative complaint, or the issuance of an
order, requiring compliance and a sanction. (Page
8: E)
For States, formal enforcement action is (1) a
referral to the State's Attorney General for the
commencement of a civil or administrative action
in the appropriate forum, or (2) the filing of an
administrative complaint, or the issuance of an
order, requiring compliance and a sanction. (Page
8: E)
Note: The enforcement action will not be checked
to determine if "sanctions" have been issued.
Since sanctions can encompass more than
penalties or SEPs, there would be no way in
the data system to correctly ensure this.
Therefore, if a formal enforcement action has
been entered, it will be assumed that the ERP
has been followed regarding appropriate
sanctions.
Informal
Enforcement
Informal Enforcement are those actions that are
not formal enforcement actions that notify the
violator of its violations. (Page 8: G)
Informal Enforcement is values 100 - 199 in
fk lu enforcemeenforcement typ located in the
cenforcement table.
Unilateral/Initial
Order
Unilateral/Initial Orders - These are issued by the
implementing agency and assert the agency's
position that violations have occurred. However,
the respondent/defendant is afforded the
opportunity to appeal the agency's determination
of violations to a trier of fact. Unilateral or Initial
Orders should be issued by Day 240. (Page 12:
section VII-A (1))
Unilateral/Initial Order means a formal enforcement
action (values 200 - 219, 250 - 259, 380 (380 is a
new enforcement code to be used when a super
CA/FO is issued pursuant to Part 22.13(b)), 510 -
559, or 590 - 599 in
fk lu enforcemeenforcement typ located in the
cenforcement table).
For addressing SNC: ONLY the following
Unilateral/Initial Orders will be used: values 200 -
219, 250 - 259, 380, 510 - 519, and 530 - 539 in
fk lu enforcemeenforcement typ located in the
cenforcement table.
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Note: A new enforcement code of 380 will be
added to RCRAInfo to capture super CA/FOs
issued pursuant to Part 22.13(b). This new
code (380) is the only way a super CA/FO
should be recorded in RCRAInfo.
Referrals to the
Department of
Justice or the State
Attorney General's
Office
Referrals to the Department of Justice or the State
Attorney General's Office - These occur when a
federal or State case is officially transmitted to
those offices for action. A federal referral is
considered to be initiated upon the signature of
the referral package by the Regional
Administrator or his/her designee, or the
Assistant Administrator for OECA, as
appropriate. With regard to the State's referral to
the Attorney General's Office, each State agency
should establish a formal process for requesting
that the Attorney General's Office initiate
enforcement proceedings on behalf of the State.
Completion of that process would then constitute
referral to the Attorney General's Office as set
forth in the time line. All referrals should be
made to the appropriate agency by Day 360.
(Page 12: section VII-A (2).)
Note: All references to the State Attorney
General's Office in this document should
be interpreted as including any State
attorney that possesses the authority to
Referrals to the Department of Justice or the State
Attorney General's Office means a formal
enforcement action (values 400 - 499 in
fk lu enforcemeenforcement typ located in the
cenforcement table).
Note: All references to the State Attorney General's
Office in this document should be interpreted
as including any State attorney that possesses
the authority to initiate actions in State court.
(Page 4: section III.)
If a State is required to send any or all of their
enforcement actions through the State
Attorney General's Office prior to issuance,
then the enforcement action should be
recorded in RCRAInfo in the appropriate
enforcement series and not in the 400 series,
(i.e., Initial Formal Administrative Actions
should be coded in the 200 series, Final
Formal Administrative Actions should be
coded in the 300 series, Civil Actions should
be coded in the 500 series, Final Judicial
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initiate actions in State court. (Page 4:
section III.)
Actions should be coded in the 600 series,
and Administrative Referrals should be coded
in the 800 series.
Final order or
Consent Order
Final or Consent Orders - These are documents
for which no appeal remains before the trier of
fact. These orders represent the agreement of the
parties involved or the decision of a trier of fact.
Final or Consent Orders should be signed by Day
360. (Page 12: section VII-A (3))
Final Order or Consent Order means a formal
enforcement action (values 300 - 319, 350 - 359, 380
or 600 - 699 in fk lu enforcemeenforcement typ
located in the cenforcement table).
Unaddressed
SV
Not specifically defined or mentioned in the ERP.
For SV Unaddressed means the site has not been
designated as a SNC (SNC located in the
hreport univ table does not have a value of 'X') and
there are one or more violations at the site with no
enforcement action, regardless of the violation's date
of determination. There is no record in
fk lu enforcemeenforcement typ, of any type/series,
linked to one or more open violations located in the
cviolation table (open violations are violations
without a date in the actual rtc date in the
cviolation table).
Addressed
SV
For SV Addressed means the implementing
agency has issued a non-penalty action that
notifies the violator of its violations. (Page 8: H)
A violator classified as a SV should NOT have a
history of recalcitrant or non-compliant conduct.
For SV Addressed means the site has not been
designated as a SNC (SNC located in the
hreport univ table does not have a value of 'X') and
there is an enforcement action issued for all
violations at the site, regardless of the violation's
date of determination. There is a record, of any
type/series, in fk lu enforcemeenforcement typ
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Violations associated with a SV should be of a
nature to allow prompt return to compliance with
all applicable rules and regulations. (Page 7:
section IV-A (2))
The objectives of an informal enforcement
response are to compel the violator to cease its
non-compliant activities and return to compliance
in the shortest possible time frame. (Page 15:
section VIII)
linked to all open violations located in the cviolation
table (open violations are violations without a date in
actual rtc date in the cviolation table).
Note: Enforcement actions used to determine SV
addressed status will not be screened
regarding penalties. Therefore, if the
enforcement action has a penalty, then it still
will be considered to meet the criteria of the
ERP as to addressing SV facilities.
Facilities will not be checked to verify the
history of the facility as related to recalcitrant
or non-compliant conduct, nor to determine if
the violation is of a nature to promptly return
to compliance with all applicable rules and
regulations. It will be assumed that the
implementer will adhere to the ERP
guidelines in making these determinations.
Unaddressed
SNC
Not specifically defined or mentioned in the ERP.
For SNC Unaddressed means the site has been
designated as a SNC (SNC located in the
hreport univ table has a value of 'X'), and the same
agency that determined the SNC has not issued a
formal enforcement action with a date on or after the
date of the SNY.
Using the cevaluation table, locate the most recent
fk lu evaluatioevaluation typ equal to 'SNY', using
that SNY record in the cevaluation table:
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1. Ensure that the value in agency equals the
responsible agency located in the cviolation
table, and the agency located in the
cenforcement table, and
2. A) For violations determined on or after
Day Zero (the evaluation date of the
last non-follow-up evaluation) by the
same agency that determined the SNY
(using the latest
fk lu evaluatioevaluation typ equal
to ' SNY' ensure that the agency of
this record equals the responsible
agency of the violation located in the
cviolation record) and there is no
formal enforcement action issued by
the agency that determined the SNY
for these violations. (There is no
record in cenforcement issued by the
same agency as the SNY (used
above), with the enforcement date
located in cenforcement on or after
the evaluation date of the SNY
record ) and
fk lu enforcemeenforcement typ
located in cenforcement does not have
a value between 200 - 219, 250 - 259,
300 - 319, 350 - 359, 380, 400 - 519,
530 - 539, 560 - 589, 600 - 699 or 800
- 899) OR
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B) If there are NO violations in the
cviolation table for this site and there
is no formal enforcement action
issued by the agency which
determined the SNY, (there is no
record in cenforcement issued by the
same agency that determined the SNY
(used above), with the
enforcement date located in
cenforcement on or after the
evaluation date of the SNY record),
then the site will be considered an
unaddressed SNC.
Note: All violations with the responsible agency in
cviolation the same as the agency of the SNY
in cevaluation which were entered on or after
Day Zero (the evaluation date of the last
non-follow-up evaluation) are looked at to
determine whether they are in full physical
compliance (has an actual rtc date) or open
(without a date in the actual rtc date in the
cviolation table). Each agency will be
responsible for addressing only its own
violations.
When RCRAInfo is updated to add the
"Addressed SNC Dated' field discussed later
in this document, this unaddressed SNC will
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begin referencing the "Addressed SNC
Dated' field rather than looking for any
action on or after the SNY date.
Addressed
SNC
For SNC Addressed means the implementing
agency has issued a formal enforcement action
that compels compliance (i.e., initial or unilateral
orders) or referred the violator to the State
Attorney General office, EPA, or the Department
of Justice and imposed appropriate sanctions. If
the SNC violations are addressed with an action
such as an order issued under RCRA §§3013 or
7003 or State equivalent authority, then the
implementing agency should follow up with an
action imposing sanctions. (Page 8: H)
For SNC Addressed means the site is a SNC (SNC
located in the hreport univ table equals 'X') and
there is a formal enforcement action issued by the
same agency that determined the SNC, and the date
of the enforcement action is on or after the date of
the SNY. Using the cevaluation table, locate the
most recent fk lu evaluatioevaluation typ equal to
'SNY', using that SNY record in the cevaluation
table:
1. Ensure that the value in agency equals the
responsible agency located in the cviolation
table, and the agency located in the
cenforcement table, and
2. For violations determined on or after Day
Zero (the evaluation date of the last non-
follow-up evaluation) by the same agency
that determined the SNY (using the latest
fk lu evaluatioevaluation typ equal to
'SNY' ensure that the agency of this record
equals the responsible agency of the
violation located in the cviolation record),
ensure that each violation has a formal
enforcement action
{fk lu enforcemeenforcement typ located in
cenforcement have a value between 200 -
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219, 250 - 259, 300 - 319, 350 - 359, 380,
400 - 519, 530 - 539, 560 - 589, 600 -699, or
800 - 899) issued by the agency that
determined the SNY. (There is a record in
cenforcement issued by the same agency as
the SNY, with the enforcement date located
in cenforcement on or after the
evaluation date of the last SNY record).
Note: A new field: "Addressed SNC Dated' will be
added to RCRAInfo Version 3. This field
will require Implementers to identify if the
enforcement action addresses a SNC and if
so, then choose: 1) the date of the appropriate
SNC designation or 2) the date of all
appropriate SNC designations from a list of
all SNY records at the site. If the
enforcement action does not address a SNC,
then the "addressed SNC dated" field will be
blank. This "Addressed SNC Dated' field
will be enforcement sensitive.
When RCRAInfo is updated to add the
"Addressed SNC Dated' field, this addressed
SNC will begin referencing the "Addressed
SNC Dated' field rather than looking for any
action on or after the SNY date.
The enforcement action will not be checked
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to determine if "sanctions" have been issued.
Since sanctions can encompass more than
penalties or SEPs, there would be no way in
the data system to correctly ensure this.
Therefore, if a formal enforcement action has
been entered, then it will be assumed that the
ERP has been followed regarding sanctions.
All violations with the responsible agency in
cviolation the same as the agency of the SNY
in cevaluation which were entered on or after
Day Zero are looked at to determine whether
they are in full physical compliance (has an
actual rtc date) or open (without a date in
the actual rtc date in the cviolation table).
Each agency will be responsible for
addressing only its own violations.
Compliance Schedule
Established
Compliance Schedule Established means that the
implementing agency has entered into a formal
enforcement agreement or a trier of fact has
issued an order, and the violator is in compliance
with its schedule. Follow-up may still be
required, depending on the situation. If a
compliance schedule is established, then the
implementing agency should monitor compliance
with that schedule; if a referral is made, then the
implementing agency should continue to monitor
the progress of the case up to and after filing.
Compliance Schedule Established means the site is a
SNC {SNC located in the hreport univ table equals
'X'), it has a formal enforcement action with an
enforceable compliance schedule, issued by the same
agency that determined the SNC and the date of the
enforcement action is on or after the SNC
determination date. Using the cevaluation table,
locate the most recent fk lu evaluatioevaluation typ
equal to 'SNY', using that SNY record in the
cevaluation table:
1. Ensure that the value in agency equals the
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Once these actions have been completed and the
violator is in compliance with its schedule, the
violator is no longer a SNC and RCRAInfo
should be updated accordingly. However, the
violator in this scenario has not returned to
compliance within the meaning of this policy.
(Page 9:1)
responsible agency located in the cviolation
table, and the agency located in the
cenforcement table, and
2. All open violations determined on or after
Day Zero (open violations are violations
without a date in actual rtc date - check the
determined date to see if it is on or after the
evaluation date of the last non-follow-up
evaluation issued by the same agency that
determined the SNY) determined by the same
agency that determined the SNY (using the
latest fk lu evaluatioevaluation typ equal to
'SNY' ensure that the agency of this record
equals the responsible agency of the
violation located in the cviolation record) and
these violations have a formal enforcement
action (fk lu enforcemeenforcement typ
located in cenforcement have a value between
300 - 319, 350 - 359, 380, 400 - 519, 530 -
539, 560 - 589, 600 - 699, or 800 - 899)
issued by the agency that determined the
SNY. (There is a record in cenforcement
issued by the same agency that determined
the SNY, with the enforcement date located
in cenforcement on or after the
evaluation date of the SNY record linked to
the open violation/s), and
3. That enforcement record has a date in the
compliance sched date located in the
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cln compliance schedule table.
The implementer should now enter an "SNN'
evaluation in Ik lu evaluatioevaluation tvp located
in the cevaluation table to remove the site from SNC
but the actual_rtc_date must remain blank until
the violation is in full physical compliance.
If the implem enter chooses not to enter the "SNN",
the site will remain a SNC and will be classified as a
"SNC With a Compliance Schedule Established".
Again, the actual_rtc_date must remain blank
until the violation is in full physical compliance.
Note: The enforcement action will not be checked
to determine if "sanctions" have been issued.
Since sanctions can encompass more than
penalties or SEPs, there would be no way in
the data system to correctly ensure this.
Therefore, if a formal enforcement action has
been entered, it will be assumed that the ERP
has been followed regarding sanctions.
A new field: "Addressed SNC Dated' will be
added to RCRAInfo Version 3. This field
will require Implementers to identify if the
enforcement action addresses a SNC and if
so, then choose: 1) the date of the appropriate
SNC designation or 2) the date of all
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appropriate SNC designations from a list of
all SNY records at the site. If the
enforcement action does not address a SNC,
then the "Addressed SNC Dated' field will be
blank. This "Addressed SNC Dated' field will
be enforcement sensitive.
When RCRAInfo is updated to add the
"Addressed SNC Dated' field, the
Compliance Schedule Established select logic
will begin referencing the "Addressed SNC
Dated' field rather than looking for any
action on or after the SNY date.
Only open violations (without a date in the
actual rtc date in the cviolation table) with
the responsible agency in cviolation the
same as the agency of the SNY in cevaluation
which were entered on or after Day Zero are
looked at. Each agency will be responsible
for addressing only its own violations.
Missed compliance schedules: see Appendix
B: "Procedure for Entering RCRAInfo Data
Pursuant to the ERP" for a discussion of what
happens when a compliance schedule
deadline has been missed.
Returned to
Returned to Compliance means that the violator is
Returned to Compliance means the actual rtc date
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Compliance
in full physical compliance with the regulatory
and/or statutory requirements. (Page 9: J)
located in the cviolation table has a date (is not
blank).
Sanctions
1) Sanctions include penalties as well as other
tangible obligations, beyond returning to
compliance (e.g., permit modifications), that are
imposed upon the owner/operator. (Page 9: K)
2) An enforcement response against a SNC by the
implementing agency should be considered
appropriate when sanctions are incorporated in
the formal enforcement response. Penalties
incorporated in the formal enforcement response
that recover the economic benefit of non-
compliance plus some appreciable amount
reflecting the gravity of the violation should be
considered appropriate. Additionally, if
warranted by the circumstances, the
implementing agency may include other sanctions
against the violator. These include, but are not
limited to: permit modifications, permit
revocation, facility shut down, and suspension
and debarment proceedings. The portion of the
penalty that does not account for the economic
benefit of non-compliance may be addressed
through the use of Supplemental Environmental
Projects (SEPs) as deemed appropriate by the
implementing agency. (Page 10: section V-A (1))
Since sanctions can encompass more than penalties
or SEPs, there would be no way in the data system to
correctly ensure this. Therefore, if a formal
enforcement action has been issued, it will be
assumed that the ERP has been followed regarding
sanctions.
Day Zero
1. Day Zero is the first day of the inspection
1. Day Zero is the evaluation date located in
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or record review regardless of the duration
the cevaluation table. In the case of these
of the inspection. In situations where there
three follow-up inspection types: (in table
are follow-up inspections at a facility, Day
cevaluation field
Zero is the first day of the first inspection.
fk lu evaluatioevaluation type would be
(Page 8: C and page 11: A)
equal to the value in parenthesis below)
- Case Development Inspection (CDI),
- Compliance Schedule Evaluation (CSE), or
- Sampling Inspection (SPL)
Day Zero will be the date of the most
recent prior non-follow-up inspection.
Non-follow-up inspections are:
- Compliance Evaluation Inspection (CEI)
- Compliance Evaluation Inspection Without
Sampling (CES)
- Compliance Assistance Activity (CAV)
- On site inspection of Corrective Action
activities (CAO)
- Compliance (Groundwater) Monitoring
Evaluation (CME)
- Compliance (Groundwater) Monitoring
Evaluation Without Sampling (CMS)
- Financial Records Review (FRR)
- Facility Self Disclosure (FSD)
- Land Ban Inspection (LBN)
- Non-Financial Records Review (NRR)
- Operation and Maintenance Inspection
(OAM)
- Other Evaluation (OTH)
And these multimedia evaluations:
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2. For violations detected through some
method other than inspection or record
reviews, Day Zero is the date upon which
the information (e.g., self-reported
violations) becomes available to the
implementing agency. (Page 11: A)
3. A. - States can also meet response criteria
and guidelines for this policy by referring
violators to EPA (Note: Day Zero for EPA
is the date of the referral). (Page 8: E) In
the case of a State referral to EPA, Day
Zero is considered the date of the referral
to EPA. (Page 11: A)
B. - The ERP does not specifically
reference what happens with EPA to State
referrals, but after consultation with ORE,
we will use the same procedure as for
State-to-EPA referrals. Which means:
EPA can also meet response
- RCRA CEI Performed with Screening
Checklist (MMB)
- Comprehensive and Coordinated Inspection
(MMC)
- Detailed Multimedia Inspection (MMD)
- Multimedia Screening Checklist Only
(MMS).
2. Day Zero is the evaluation date of the Facility
Self Disclosure record
(fk lu evaluatioevaluation type = FSD
located in the cevaluation table).
3. A. - this referral is value 810 in
fk lu enforcemeenforcement typ and the new
Day Zero for EPA would be the
enforcement date of the 810 record. Both of
these fields are located in the cenforcement
table.
B. - this referral is value 820 in
fk lu enforcemeenforcement typ and the new
Day Zero for the State would be the
enforcement date of the 820 record. Both of
these fields are located in the cenforcement
table.
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criteria and guidelines for this
policy by referring violators to the
State. (Note: Day Zero for the
State is the date of the referral). In
the case of a EPA referral to State,
Day Zero is considered the date of
the referral to the State. (Not
specifically mentioned in the ERP)
Note: Since the issuance of the
ERP and this appendix, the Office
of Regulatory Enforcement (ORE)
has changed its name to the Office
of Civil Enforcement (OCE).
4. In the case of SV facilities that have failed
to return to compliance, Day Zero will be
the date that the violator is reclassified as
a SNC. (Page 11: A)
5. In the case of j oint State/EPA
enforcement actions, Day Zero is the date
the EPA inspection report/referral is
received when the State has the lead for
the enforcement action. (Page 8: E)
4. See Appendix B: "Procedure for Entering
RCRAInfo Data Pursuant to the ERP" for a
discussion of what happens when a SV
facility is reclassified as a SNC.
5. Currently RCRAInfo does not contain a
specific/separate field for Day Zero, therefore
there is no way to determine when EPA sent
or the state received the EPA inspection
report. Therefore, Day Zero will be the date
of the evaluation as outlined above in #1 of
the Day Zero discussion.
Note: Currently RCRAInfo does not contain a
specific/separate field for Day Zero. When
RCRAInfo is updated to include the
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recommendations of the Handler Monitoring
Assistance Program Area Analysis (HMA
PAA) work, a new field: day zero will be
added in the evaluation record and will be set,
by the implementer, according to the
provisions of the ERP. Once this new field
(day zero) is available in RCRAInfo, it will
be used exclusively to define Day Zero and
we will no longer derive Day Zero from the
last non-follow-up evaluation. This
"Day Zero" field will be enforcement
sensitive.
Date of
Determination
(Day 150)
1. The Date Determined is a date no later
than 150 days after Day Zero by which
the implementing agency first determines
that a violation has occurred. This
evaluation includes determining the
facility's compliance with the regulations
and then determining whether the violator
is a SNC or SV. To the extent that the
violation(s) meet one or more of the
elements of the SNC definition, the
violator should be designated a SNC and
subject to the appropriate formal
enforcement response of this policy (see
Section V.A. above). If the violations do
not meet the criteria for designation as a
SNC, then the violator should be
1. Date of Determination is the violation
determined date located in the cviolation
table. This must be entered into RCRAInfo
as soon as possible, but at least by 150 days
after Day Zero.
By day 150 (150 days after Day Zero), if the
site is designated a SNC, then an SNY
evaluation record must be entered in
RCRAInfo with the date the SNC decision
was made as the evaluation date of the SNC
record (fk lu evaluatioevaluation typ equal
to ' SNY' with the evaluation date equal to
the date of the SNC determination. Both
fields are located in the cevaluation table). If
the site is not designated a SNC, then nothing
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designated a SV and subject to, at a
minimum, an informal enforcement
response of this policy (see Section V.B
above). The implementing agency should
enter the facility as a SNC or a SV into
RCRAInfo at this time. (Page 11: B)
Date of Determination (Day 150) is the
final date to determine if formal
enforcement is appropriate. (Page 8: D)
2. By Day 150, the implementing agency
should issue a warning letter or other
appropriate notification of violations to
those violators designated as SVs or SNCs
to put those violators on notice of their
violations. A notice of inspection or other
written notification provided at the time of
the inspection will be considered to have
put the violator on notice. If the EPA or
State determines that a facility is a SNC,
then the warning letter or other form of
notification should advise the facility of
its status. The SNC determination should
also be entered into RCRAInfo by this
date. (Page 12: C)
needs to be entered in RCRAInfo.
2. By day 150 (150 days after Day Zero), a
warning letter or other appropriate
enforcement action should be issued:
For SVs: The site has not been designated as
a SNC (SNC located in the hreport univ table
does not have a value of 'X') and there is an
enforcement action issued for all open
violations at the site, regardless of the
violation's date of determination (there is a
record, of any type/series, in
fk lu enforcemeenforcement typ linked to all
open violations located in the cviolation table
(open violations are violations without a date
in actual rtc date in the cviolation table)).
For SNCs: The site is a SNC (SNC located in
the hreport univ table equals 'X') and there
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is at least an informal enforcement action,
issued by the same agency that determined
the SNC for all violations determined on or
after Day Zero, and the date of the
enforcement action is on or after the SNC
determination date (using the cevaluation
table, locate the most recent
jk lu evaluatioevaluation typ equal to
'SNY', using that SNY record in the
cevaluation table:
- Ensure that the value in agency equals
the responsible agency located in the
cviolation table, and the agency
located in the cenforcement table, and
- For violations determined on or after
Day Zero by the same agency that
determined the SNY (using the latest
jk lu evaluatioevaluation typ equal
to ' SNY' ensure that the agency of
this record equals the
responsible agency of the violation
located in the cviolation record),
ensure that each violation has at least
an informal enforcement action
(fk lu enforcemeenforcement typ
located in cenforcement have a value
between 100 - 199 or a value greater
than 199) issued by the agency that
determined the SNY (there is a record
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in cenforcement issued by the same
agency that determined the SNY, with
the enforcement date located in
cenforcement on or after the
evaluation date of the SNY record.))
Note: All violations with the responsible agency in
cviolation the same as the agency of the SNY
in cevaluation which were entered on or after
Day Zero are looked at to determine whether
they are in full physical compliance (has an
actual rtc date) or open (without a date in
the actual rtc date in the cviolation table).
Each agency will be responsible for
addressing only its own violations.
Day 240
1. By Day 240, the implementing agency
should issue its unilateral or initial orders
to the designated SNCs, if appropriate,
(Orders which follow NOVs are
considered initial orders in this instance.)
(Page 12: D)
1. By day 240 (240 days after Day Zero), for a
SNC facility (SNC located in the
hreport univ table equals 'X') there is a
unilateral/initial enforcement order issued by
the same agency that determined the SNC,
and the date of the enforcement action is on
or after the SNC determination date (using
the cevaluation table, locate the most recent
fk lu evaluatioevaluation typ equal to
'SNY', using that SNY record in the
cevaluation table:
- Ensure that the value in agency equals
the responsible agency located in the
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cviolation table, and the agency
located in the cenforcement table, and
- For violations determined on or after
Day Zero by the same agency as the
SNY (using the latest
fk lu evaluatioevaluation typ equal
to ' SNY' ensure that the agency of
this record equals the
responsible agency of the violation
located in the cviolation record)
ensure that each violation has a
unilateral/initial enforcement order
(fk lu enforcemeenforcement typ
located in cenforcement has a value
between (values 200 - 219, 250 - 259,
or 380 (380 is a new enforcement
code to be used when a super CA/FO
is issued pursuant to Part 22.13(b)),
or 510 - 519, or 530 - 539) issued by
the agency that determined the SNY
(there is a record in cenforcement
issued by the same agency as the
SNY, with the enforcement date
located in cenforcement on or after
the evaluation date of the SNY
record.)
Note: A new enforcement code of 380 will be
added to RCRAInfo to capture super CA/FO s
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2. By Day 240, SVs are required to return to
compliance. (Page 12: D)
3. For SVs: If the violator does not come
into compliance within 240 days of Day
Zero, then the implementing agency
should reclassify the facility as a SNC, if
appropriate. (Page 10: B)
issued pursuant to Part 22.13(b). This new
code (380) is the only way a super CA/FO
should be recorded in RCRAInfo.
2. By day 240 (240 days after Day Zero), for
SVs, (SNC located in the hreport univ table
does not have a value of 'X') all violations at
the site, regardless of the violation's date of
determination, have returned to full physical
compliance. (There are no open violations
located in the cviolation table (open
violations are violations without a date in
actual rtc date in the cviolation table)).
3. See Appendix B: "Procedure for Entering
RCRAInfo Data Pursuant to the ERP" for a
discussion of what happens when a SV
facility is reclassified as a SNC.
Note: The enforcement action will not be checked
to determine if "sanctions" have been issued.
Since sanctions can encompass more than
penalties or SEPs, there would be no way in
the data system to correctly ensure this.
Therefore, if a formal enforcement action has
been entered, it will be assumed that the ERP
has been followed regarding sanctions.
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A new field: "Addressed SNC Dated' will be
added to RCRAInfo Version 3. This field
will require Implementers to identify if the
enforcement action addresses a SNC and if
so, then choose: 1) the date of the appropriate
SNC designation or 2) the date of all
appropriate SNC designations from a list of
all SNY records at the site. If the
enforcement action does not address a SNC,
then the "Addressed SNC Dated' field will be
blank. This "Addressed SNC Dated' field will
be enforcement sensitive.
All violations with the responsible agency in
cviolation the same as the agency of the SNY
in cevaluation which were entered on or after
Day Zero are looked at to determine whether
they are in full physical compliance (has an
actual rtc date) or open (without a date in
the actual rtc date in the cviolation table).
Each agency will be responsible for
addressing only its own violations.
Enforcement actions used to determine SV
addressed status will not be screened
regarding penalties. Therefore, if the
enforcement action has a penalty, then it still
will be considered to have met the criteria of
the ERP as to addressing SV facilities.
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Day 360
By Day 360, the implementing agency should
make a referral to the Department of Justice or
State's Attorney General office or enter into a
final order with the violator. (Page 12: E)
By day 360 (360 days after Day Zero), if the site is a
SNC (SNC located in the hreport univ table equals
'X') then there is either a referral to the Department
of Justice or State's Attorney General office or a
final order issued by the same agency that
determined the SNC, and the date of the enforcement
action is on or after the SNC determination date.
Using the cevaluation table, locate the most recent
jk lu evaluatioevaluation typ equal to 'SNY', using
that SNY record in the cevaluation table:
- Ensure that the value in agency equals
the responsible agency located in the
cviolation table, and the agency
located in the cenforcement table, and
- All violations determined on or after
Day Zero by the same agency that
determined the SNY (using the latest
jk lu evaluatioevaluation typ equal
to ' SNY' ensure that the agency of
this record equals the
responsible agency of the violation
located in the cviolation record) have
a referral to the Department of Justice
or State's Attorney General office or a
final order
(fk lu enforcemeenforcement typ
located in cenforcement have a value
between 300 - 319, 350 - 359, 380, or
400 - 499, or 600 - 699) issued by the
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agency which determined the SNY
(there is a record in cenforcement
issued by the same agency as the
SNY, with the enforcement date
located in cenforcement on or after the
evaluation date of the SNY record.)
Note: A new enforcement code of 380 will be
added to RCRAInfo to capture super CA/FOs
issued pursuant to Part 22.13(b). This new
code (380) is the only way a super CA/FO
should be recorded in RCRAInfo.
The enforcement action will not be checked
to determine if "sanctions" have been issued.
Since sanctions can encompass more than
penalties or SEPs, there would be no way in
the data system to correctly ensure this.
Therefore, if a formal enforcement action has
been entered, it will be assumed that the ERP
has been followed regarding sanctions.
A new field: "Addressed SNC Dated' will be
added to RCRAInfo Version 3. This field
will require Implementers to identify if the
enforcement action addresses a SNC and if
so, then choose: 1) the date of the appropriate
SNC designation or 2) the date of all
appropriate SNC designations from a list of
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all SNY records at the site. If the
enforcement action does not address a SNC,
then the "Addressed SNC Dated' field will be
blank. This "Addressed SNC Dated' field will
be enforcement sensitive.
All violations with the responsible agency in
cviolation the same as the agency of the SNY
in cevaluation which were entered on or after
Day Zero are looked at to determine whether
they are in full physical compliance (has an
actual rtc date) or open (without a date in
the actual rtc date in the cviolation table).
Each agency will be responsible for
addressing only its own violations.
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Page 27 of 34
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To summarize:
Evaluation
Date
(is Day Zero)
first day of
last
non-follow-up
evaluation
{evaluation date)
" max. time "
150 days from
Day Zero
All violations
determination
entered, into RCRAInfo
aand at least an informal
enforcement action issued
notifying facility of their
violations and SNC status,
4~ max. time ¦
240 days from
Day Zero
t~ max. time H
360 days from
Day Zero
T ""ite^A/FO
Initial c5raer, or
issued. sV must
be in full physical
compliance with all
open violations as reflected in
RCRAInfo, or the facility should
be re-evaluated to determine if the
facility should be reclassified as a
SNC and the SNY entered into
er or
DOJ or AG,
issued
Note: For SVs: The timely and appropriate time line ends at Day 240, regardless of whether or not all violations are returned to
compliance or the facility is re-evaluated by the implementer to determine if the facility should be re-classified as a SNC.
Once the implementer has re-evaluated the facility it should enter the appropriate response. Based on this re-evaluation (either
a SNC determination or other action to bring the facility into full physical compliance) a new time line may begin.
For SNCs: The timely and appropriate time line ends at:
1. Day 240 if a Super CA/FO (enforcement action type 380) is entered, or
2. If no Super CA/FO is entered, at Day 360 with the issuance of a Final Order or a Referral to DOJ or the AG,
whether or not all violations at the facility have returned to compliance.
if appli5£l$te facility does not return all violations to full physical compliance, then the implementer should re-evaluate the facility
pursuant to the guidelines of the ERP.
Follow-up inspections are:
1) Case Development Inspection (CDI),
2) Compliance Schedule Evaluation (CSE), or
3) Sampling Inspection (SPL).
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Page 28 of 34
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Non-follow-up inspections are: 1) Compliance Evaluation Inspection (CEI),
2) Compliance Evaluation Inspection Without Sampling (CES),
3) Compliance Assistance Activity (CAV),
4) On site inspection of Corrective Action activities (CAO),
5) Compliance (Groundwater) Monitoring Evaluation (CME),
6) Compliance (Groundwater) Monitoring Evaluation Without Sampling (CMS),
7) Financial Records Review (FRR),
8) Facility Self Disclosure (FSD),
9) Land Ban Inspection (LBN),
10) Non-Financial Records Review (NRR),
11) Operation and Maintenance Inspection (OAM),
12) Other Evaluation (OTH),
13) RCRA CEI Performed with Screening Checklist (MMB),
14) Comprehensive and Coordinated Inspection (MMC),
15) Detailed Multimedia Inspection (MMD), and
16) Multimedia Screening Checklist Only (MMS).
Note: Response times articulated in the ERP should be adhered to by the Regions and States to the greatest extent possible.
However, there are recognized circumstances that may dictate an exceedance of the standard response times. A ceiling of 20%
per year has been established for consideration of cases involving unique factors that may preclude the implementing agency
from meeting the standard response times. (Page 12: section VII-B)
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Appendix B: Procedure for Entering
RCRAInfo Data Pursuant to the ERP
An essential part of the ERP is assuring that all information is promptly and correctly entered
into RCRAInfo. Therefore, we are attaching this data entry appendix as a further clarification of
the December 2003 ERP. Should you have any questions regarding this appendix, please contact
Debbie Goodwin (202-564-0057) from OC's Data Systems and Information Management
Branch.
1. Entering Evaluations/Inspections: The first step in the data entry process is to enter the
"Evaluation Type," including the "Date of Evaluation" which is the first day of the
evaluation or records review regardless of how long the evaluation takes. This date is
Day Zero and will be the beginning point for calculations for all timely and appropriate
enforcement responses. The "Evaluation Type" and the "Evaluation Date" are entered
into the cevaluation table via the Evaluation Add/Update Screen. The evaluation should
be entered into RCRAInfo as soon as possible but must be done immediately after the
evaluation is completed.
2. Entering Violations: The next step is to determine whether or not the evaluation found
violations. This determination should be done as quickly as possible and entered into
RCRAInfo, but this must occur within 150 days of Day Zero. This is done on the
Evaluation Add/Update Screen by responding to the question: "Did this evaluation find
violations?" The answers are: 1) "Yes, violations were discovered", 2) "No, violations
were not found', or 3) "Undetermined, agency is still working on determining
violations". Violations determined during the same evaluation can have different
determined dates, as the violations can be determined at any stage during the evaluation.
Violations should be entered into RCRAInfo as soon as they are determined, even if the
agency is waiting for information on additional violations. The additional violations can
be entered at a later time when the agency receives the additional information to
determine, if in fact, they are violations.
3. Entering SNC Determination: When one or more violations are identified, the Region
or State has 150 days from Day Zero to determine whether the violator is a Significant
Non-Complier (SNC) or a secondary violator (SV).
If the violator is classified as a SV, then no data entry is necessary at this time.
If the violator is a SNC, then the agency must enter a new "SNY" evaluation record
into RCRAInfo with the evaluation date equal to the date that the agency determined
that the facility was a SNC. These are entered into the cevaluation table via the
Evaluation Add/Update Screen. The SNC evaluation should be entered into RCRAInfo
as soon as possible but must be done within 150 days from Day Zero. When RCRAInfo
Version 3 is released (Spring 2005) there will a new enforcement sensitive data entry
Appendix B: Procedure for Entering RCRAInfo Data pursuant to the December 2003 ERP
Final March 23, 2005 Page 30 of 34
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field added to the evaluation record: "Day Zero". This field will be entered by
Implementers when an SNY or SNN evaluation record is entered into RCRAInfo. This
should be done by selecting the appropriate date from a drop-down box which will
display the following:
1. a listing of all non-follow-up evaluations at the site,
2. a list of State-to-EPA referrals or EPA-to-State referrals, or
3. "reclassified as SNC": This would only be used when a SV site is
reclassified as a SNC, since the Implementer would need to provide
(through direct data entry) the date of the reclassification. Once
"reclassified as SNC" was chosen from the drop-down box, the
Implementer would be able to enter a date into the "Day Zero" field.
4. Entering Enforcement Actions: Immediately upon issuance of an enforcement action
(informal or formal), and for every enforcement action, information must be entered into
RCRAInfo, regardless of whether the facility is a SV or SNC. When the enforcement
action has been issued, RCRAInfo should be updated via the Enforcement Add/Update
Screen, with the "Type of Enforcement Action", "Date of Enforcement Action", and, if
the enforcement action put the facility on a compliance schedule, the "Scheduled
Complete Date". When RCRAInfo Version 3 is released (Spring 2005) there will be a
new enforcement sensitive data entry field added to the enforcement record: "Addressed
SNC Dated". This field should be entered by Implementers when an enforcement
action/order addresses a SNC. This should be done by selecting: 1) the date of the
appropriate SNC designation or 2) the date of all appropriate SNC designations from a
drop-down box which will display all SNC designations, made by that agency, for the
site (SNY evaluation records for the agency as performing the data entry).
Note: The evaluation date of the SNY record, the enforcementdate, along with new
"Day Zero", and the new "Addressed SNC Dated" field, are used to calculate timely and
appropriate enforcement response.
For SNCs: Once all open violations are put on a compliance schedule, the implementer
should enter an "SNN" evaluation with the date that the last open violation was placed on
a compliance schedule as the "Evaluation Date" of the "SNN" evaluation record. But
the actualrtcdate must remain blank until the violation is in full physical
compliance. If the implementer chooses not to enter the "SNN", the site will remain a
SNC and will be classified as a "SNC With a Compliance Schedule Established". Again,
the actual rtc date must remain blank until the violation is in full physical
compliance.
Note: Only the agency that turned on the SNC (determined the SNC by entering the
SNY) can turn off the SNC designation (enter the SNN).
Missed Compliance Schedules: For purposes of data entry, if a SNC is placed on a
compliance schedule and an "SNN" is entered but the facility misses its compliance
Appendix B: Procedure for Entering RCRAInfo Data pursuant to the December 2003 ERP
Final March 23, 2005 Page 31 of 34
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schedule, the implementer should re-evaluate the facility and determine if a new SNC
designation should be entered. If a new SNC designation is warranted, then see step # 3
above for instructions on how to enter the "SNY" evaluation.
Failure to comply with an order: If a facility fails to comply with an order, then the
implementer should re-evaluate the facility to determine the next course of action. If a
new SNC designation is warranted, then see step # 3 above for instructions on how to
enter the "SNY" evaluation.
5. Entering Returned to Full Physical Compliance: When a violation, whether at a SNC
or SV, returns to full physical compliance, the agency should update RCRAInfo with the
"Actual Returned to Compliance Date". This is entered into the cviolation table and can
be done in three different ways: 1) the Evaluation Add/Update Screen, 2) the Violation
Update Screen, or 3) the Enforcement Add/Update Screen.
If all violations at a SNC facility have returned to full physical compliance, the SNC
facility is in compliance and if a "SNN" evaluation record has not already been entered
into RCRAInfo for this facility, a "SNN" evaluation record, with the evaluation date of
the "SNN" being the date when all violations returned to compliance, should be entered
by the same agency that determined the SNC. This is done via the Evaluation
Add/Update Screen.
If all violations at a SV have returned to full physical compliance, then the SV facility is
in compliance and no further action is required.
A facility designated as a SV must return to full physical compliance (RTC) with the
statutory and/or regulatory requirements by Day 240 (240 days from Day Zero). If the
SV facility still has one or more violations out of full physical compliance, then it has not
returned to full physical compliance within the 240 days and the facility should be re-
evaluated by the implementer to determine if a SNC designation is warranted. If a new
SNC designation is warranted, then see step # 3 above for instructions on how to enter
the "SNY" evaluation.
In summary, "SNY" evaluations are only to be entered for violations which are determined to be
SNCs. "SNN" evaluations should be entered only for SNCs which have "Returned to
Compliance" or are on an enforceable compliance schedule. This means either the facility is in
full compliance with regulatory and/or statutory requirements or they are in full compliance with
a compliance schedule established via a formal enforcement action (either an order or an
agreement).
Appendix B: Procedure for Entering RCRAInfo Data pursuant to the December 2003 ERP
Final March 23, 2005 Page 32 of 34
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SNC Select Logic for setting SNC in RCRAInfo:
The field SNC in the table hreport univ is used to track SNCs and is automatically set every 3
hours during the execution of the Universe calculation program. This universe type is nationally
defined, required, and releaseable. Note: no pre-FY '91 data will be used.
Criteria
Definition of SNC: is a facility that has a SNY evaluation record which has not been superseded
by a SNN record entered by the same agency as the SNY.
In RCRAInfo
(evaluationdate in cevaluation table of the latest fkluevaluatioevaluationtype = 'SNY" is
greater than the evaluation date in cevaluation table of the latest fk lu evaluatioevaluation type
= 'SNN" with the same agency in cevaluation table for both SNY and SNN records)
OR
(There is a fk lu evaluatioevaluation type = 'SNY" with no fk lu evaluatioevaluation type =
'SNN" by the same agency)).
Note: This is the select logic which is to be used to determine current SNCs and to determine
who was a SNC in any period of time since 10/01/96 (FY '97). We will no longer be
checking for open violations (violations with no actualrtcdate), class 1 priority 9
violations, or compliance schedule dates in order to determine SNCs.
To determine who was a SNC in any period of time between 10/01/90 (FY '91) and 09/30/96
(FY '96) the following select logic will be used:
Criteria for Historic SNCs between 10/01/90 (FY '91) and 09/30/96 (FY '96):
To define who was a SNC at any period between 10/01/90 (FY '91) and 09/30/96 (FY '96), look
at the violations determined during the time period and check to see if they were a class " 1"
priority "9" violation and if they were out of compliance during the time period (either out of full
physical compliance or compliance with their compliance schedule). If there were, then the
facility was a SNC during the time period.
In RCRAInfo:
Using the cviolation table check to see if there is a record with: determineddate
between the time periods and fk lu classclass type = ' 1" and
fk_lu_prioritypriority_type = '9" and ((actual rtc date is blank or greater than the
determined date) or (compliancescheddate is blank or compliancescheddate
has passed)), then the facility was a SNC during the time period.
Note: Once RCRAInfo Version 3 is released (currently scheduled for August 2005), all sites
that are SNCs per the FY '91 - FY '96 SNC definition above, will automatically have a
Appendix B: Procedure for Entering RCRAInfo Data pursuant to the December 2003 ERP
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SNY evaluation record created with a comment in the Notes field in the cevaluation table
explaining that this record was created because of conversion of Class 1 Priority 9
violation on xx/xx/xx (evaluation date of violation) and other information describing the
violation. This will capture all sites which are in SNC because of the old definition AT
THE TIME OF THE CONVERSION to RCRAInfo Version 3. This is being done to
facilitate the new definition of only using SNY/SNN to determine SNC and to delete the
class and priority fields from the cevaluation table. Once this automatic conversion is
completed, it will be up to each Implementer to enter an SNN evaluation record to turn
these SNCs off when they return to compliance. There will not be any automated process
to add the SNN.
Also, once RCRAInfo Version 3 is release, if there is an SNY and an SNN on the same
day entered by the same agency and in the Notes field for the SNY record the first words
are "Site should not be a SNC", the site will not be considered a SNC for that day. If
the Notes field for that record does not have as the first words "Site should not be a
SNC", the site will be considered a SNC from that day until another SNN evaluation
record is entered by that agency. This will provide for the situations when a site is
determined to be a SNC and entered into RCRAInfo as a SNC, and then later the
Implementer determines that the original SNC determination was an error. Since we can
not delete the SNY determination because it did actually occur and may have been
reported, by using this method we can correct the error and RCRAInfo and public access
sites will not report the site as having been in SNC for the time between when the error
occurred and when it was corrected.
Appendix B: Procedure for Entering RCRAInfo Data pursuant to the December 2003 ERP
Final March 23, 2005 Page 34 of 34
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