Reno AFS2002
f[ahoe National Conference
CMS Training
Monday, June 10, 2002
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Reno
ITanoe
I zoozl
AFS 2002
National Conference
CMS Training Agenda
Monday June 10 r 2002
3:00pm - 4:00pm CMS - Implementation in AFS
CMS Update & Browse screens
Sample Ad Hoc Reports
CMS Technical Support document
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Section 1 - CMS PowerPoint presentation
Section 2 - CMS Update and Browse screens
Section 3 - Sample CMS Ad Hoc Reports
Section 4 - CMS Technical Support Document
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Section 1
CMS
Implementation in AFS
-------
CMS Training
AFS 2002
June 10, 2002
^oST/%>
KZJ
Compliance Monitoring
Strategy
Implementation into AFS
Section 1: CMS Reporting
1.1 Facility Identification
1.2 Compliance Evaluation Tracking
1.3 Title V Annual Compliance Certifications
1.4 Stack Tests
1.5 Minimum Frequencies
1.6 Unknown Compliance Status
1.7 Scheduled FCE's
1.8 Scheduled vs Completed FCE's
2
1
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CMS Training
AFS 2002
June 10, 2002
Section 2: AFS Enhancements
2.1 Modification to default Compliance
status (completed May 2001)
2.2 Modification to default Classification
(completed May 2001)
2.3 Removal of date & type of last
inspection
3
STATE COMPLIANCE STATUS
6 - NOT MEETING EPA COMPLIANCE STATUS : 3 - IN COMPL
STATE CLASSIFICATION . .
A EPA CLASSIFICATION .. : B
OPERATING STATUS
O - OPERATIN
CONTINUOUS EMISSIONS ..
PRIORITY CODE
-
STATE REGISTRATION # ..
SRD=FEE ID
GOVT. FACILITY CODE ...
0 - ALL OTHER FACILITIES NOT OWNED OR OPER. BY F
FACILITY CAPACITY
CAPACITY UNITS:
CONTACT PERSON
( )
PLANT DESCRIPTION
RICE MILLING-MFRS
LAST STATE INSP. ACTION
07 DATE (YYMMDD): 960122
LAST EPA INSP. ACTION
DATE (YYMMDD):
PRIVATE(Y/N): N
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF6=PGUP PF12=UPDT SCREEN: 050
4
2
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CMS Training
AFS 2002
June 10, 2002
Section 2: AFS Enhancements
2.4 New CMS Record
- Update screen 315
- Browse screen 516
- Batch transaction 18
5
DATE : 02/05/01
SCREEN: 516
AIRS FACILITY SUBSYSTEM
PLANT COMPLIANCE MONITORING
- BROWSE PGM:
STRATEGY MAP:
AFPxxx
AFMxxxx
00006 SAMPLE PLANT
NOT ANYWHERE ROAD
CMS SOURCE CATEGORY: A
TITLE V MAJOR
CMS MINIMUM FREQUENCY INDICATOR: 2
FISCAL YEAR OF FCE
YEAR A
2004 ON-SITE VISIT
PLANNED (Y/N): Y
FISCAL YEAR OF FCE
YEAR B
ON-SITE VISIT
PLANNED (Y/N):
FISCAL YEAR OF FCE
YEAR C
ON-SITE VISIT
PLANNED (Y/N):
FISCAL YEAR OF FCE
YEAR D
ON-SITE VISIT
PLANNED (Y/N):
FISCAL YEAR OF FCE
YEAR E
ON-SITE VISIT
PLANNED (Y/N):
COMMENT:
LATEST STATE FULL COMPLIANCE EVALUATION ACTION :
DATE (YYYYMMDD)
9999/99/99
LATEST EPA FULL COMPLIANCE
EVALUATION ACTION :
DATE (YYYYMMDD)
9999/99/99
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF12=UPDATE
SCREEN: 050
6
3
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CMS Training
AFS 2002
June 10, 2002
-13 new Input fields
CMS Source Category (CMSC)
CMS Minimum Frequency Indicator (CMSI)
(5) Fiscal Year of FCE (CMYA - CM YE)
(5) On-Site Visit Indicator (CMOA - CMOE)
CMS Comment (CM19)
2.4 New CMS Record (con't)
-21 new retrieval acronyms
-13 Input fields
Plus
-10 retrieval only fields
CMS Source Category Description (CMSD)
State FCE Type (SFT1) State FCE Date (SFD1)
EPA FCE Type (EFT1) EPA FCE Date (EFD1)
Default FCE Type (DFT1) Default FCE Date (DFD1)
Special Ad-hoc acronym (CMFY)
Person Updating Record (PU19)
Date Record is Updated (DU19)
8
4
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CMS Training
AFS 2002
June 10, 2002
Section 2: AFS Enhancements (com)
2.6 Automatic generation of unknown
compliance status if an FCE is not
completed in accordance with CMSI
> Major facilities (including mega sites)
>Air program = Title V
^Pollutant = FACIL
>EPA Compliance Status = U
> 80% SM
>Air program = FESOP or SIP
>Pollutant= FACIL
>EPA Compliance Status = U 9
DATE : 04/2 6/01 AIRS FACILITY SUBSYSTEM - UPDATE PGM: AFP303
SCREEN: 30 3 PLANT POLLUTANT AIR PROGRAMS MAP: AFM3032
00 00 6 SAMPLE PLANT NOT ANYWHERE ROAD
*STATE POLLUTANT COMPLIANCE STATUS: 3 EPA POLLUTANT COMPLIANCE STATU
STATE POLLUTANT CLASSIFICATION : A_ EPA POLLUTANT CLASSIFICATION .. :
STATE ATTAINMENT/NON-ATTAINMENT : EPA ATTAINMENT/NON-ATTAINMENT :
LOADING DERIVATION CODE : _ RDE 14 : 2
TOXICITY LEVEL :
STATE REGULATION NUMBER :
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF9=DUPL PF10=SCRN PF12=BRWS SCREEN: 040
10
5
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CMS Training
AFS 2002
June 10, 2002
Section 2: AFS Enhancements (com)
2.7 Removal of Previously Generated
Unknown Compliance Status
2.8 New or modified action codes
> Full Compliance Evaluation with on-site visit
> Full Compliance Evaluation w/o on-site visit
> Partial Compliance Evaluations with on-site visit
> Partial Compliance Evaluations w/o on-site visit
> Investigations
> Stack Tests
> Title V Annual Compliance Certifications
11
Section 2: AFS Enhancements (com)
2.9 New Results Codes
> Review of Title V Annual Compliance Certifications
>ln Compliance
>ln Violation
> Unknown
> Stack Tests
>Pass
>- Fail
2.10 Full Compliance Evaluation Pathway
12
6
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CMS Training
AFS 2002
June 10, 2002
DATE : 04/26/01
SCREEN: 306
AIRS FACILITY SUBSYSTEM - UPDATE PGM: AFP306
PLANT ACTIONS MAP: AFM3062
00006 SAMPLE PLANT
NOT ANYWHERE ROAD
*ACTION: 001
KEY ACTION (Y/N): N
*AIR PROGRAM CODE(S) ..
V KEY ACTION(S):
*ACTION TYPE
ACTION DESCRIPTION ...
DATE SCHEDULED (YYMMDD)
ACTION TYPE CATEGORY :
DATE ACHIEVED (YYMMDD) :
POLLUTANT CODE
CHEMICAL ABSTRACT # .. :
CONTRACTOR ID
_
RDE 16
PRIVATE(Y/N): N
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF9=DUPL PF10=SCRN PF12=BRWS SCREEN: 040
13
Section 2: AFS Enhancements (con't)
2.11 Special Ad-hoc Acronym (CMFY)
Acronym
Condition
Value
SUE
ME
XX
CMYA
CE
2000
CMYB
CE
2000
CMYC
CE
2000
CMYD
CE
2000
CMYE
CE
2000
DFD1
LE
990930
DFD1
GE
001001
Acronym
Condition
Value
STTE
ME
XX
CMFY
ME
2000
14
7
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CMS Training
AFS 2002
June 10, 2002
15
8
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Section 2
CMS Screens
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Update CMS - Screen 315
DATE : 05/15/02 AIRS FACILITY SUBSYSTEM - UPDATE PGM: AFP315
SCREEN: 315 COMPLIANCE MONITORING STRATEGY MAP: AFM3151
SUSAN SUSAN'S PLANT 99999
( 2001/08/28 - JH1 )
CMS SOURCE CATEGORY: _
CMS MINIMUM FREQUENCY INDICATOR: _
PLANNED YEAR (S) OF FULL COMPLIANCE EVALUATION (FCE) :
FISCAL
YEAR
A
ON-SITE
VISIT
PLANNED
(Y/N)
FISCAL
YEAR
B
ON-SITE
VISIT
PLANNED
(Y/N)
FISCAL
YEAR
C
ON-SITE
VISIT
PLANNED
(Y/N)
FISCAL
YEAR
D
ON-SITE
VISIT
PLANNED
(Y/N)
FISCAL
YEAR
E
ON-SITE
VISIT
PLANNED
(Y/N)
COMMENT:
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF10=SCRN SCREEN:
Browse CMS - Screen 516
DATE : 05/15/02
AIRS FACILITY SUBSYSTEM - BROWSE
PGM:
AFP516
SCREEN: 516
COMPLIANCE
MONITORING STRATEGY
MAP:
AFM5161
SUSAN SUSAN'S PLANT
99999
2002/05/15
- KGJ )
CMS SOURCE CATEGORY:
CMS MINIMUM FREQUENCY INDICATOR:
PLANNED YEAR(S) OF
FULL COMPLIANCE EVALUATION (FCE) :
FISCAL YEAR
A
ON-SITE
VISIT PLANNED (Y/N)
FISCAL YEAR
B
ON-SITE
VISIT PLANNED (Y/N)
FISCAL YEAR
C
ON-SITE
VISIT PLANNED (Y/N)
FISCAL YEAR
D
ON-SITE
VISIT PLANNED (Y/N)
FISCAL YEAR
E
ON-SITE
VISIT PLANNED (Y/N)
COMMENT:
LATEST STATE FCE
ACTION: 16 DATE
(YYYYMMDD): 19981201
LATEST EPA FCE ACTION : DATE
(YYYYMMDD) :
PF1=HELP PF3=END
PF4=MAIN PF5=TERM PF10=SCRN
SCREEN:
1
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Section 3
Sample Ad Hoc Criteria sets
for
CMS Reports
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GENERAL REPORT INFORMATION:
USER ID: MUX
REPORT NAME: AB021
FORMAT TYPE: Ml
TITLE: COMPLIANCE STATUS IN ALBUQUERQUE, NM
SELECTION CRITERIA:
REGN ME 0 6
PCDS NB
STAB ME NM
CNTY ME 001
APC1 NE 3
OPST CE O
OPST CE T
OPST CE I
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
DDS1
DCL1
HEADINGS FOR COLUMNS:
A
SM
B
C
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 4 30
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
DATE: 01/08/02
AIRS FACILITY SUBSYSTEM QUICK LOOK MILESTONE REPORT
COMPLIANCE STATUS IN ALBUQUERQUE, NM
SENSITIVE AMD DRAFT SIP DATA INCLUDED
PAGE:
2
ALL DATA
DCL1
DCL1
DCL1
DCL1
DDS1
TOTAL
A
SM
B
C
IN COMPLIANCE - INSPECTIO
27
0
0
27
0
IN COMPLIANCE WITH PROCED
571
12
14
543
2
IN VIOLATION WITH REGARD
11
0
1
10
0
MEETING COMPLIANCE SCHEDU
1
0
1
0
0
NO APPLICABLE STATE REGUL
1
0
0
1
0
UNKNOWN WITH REGARD TO PR
11
0
0
11
0
622 12 16 592 2
# ITEMS:
6
-------
GENERAL REPORT INFORMATION:
USER ID: MUX
REPORT NAME: AB022
FORMAT TYPE: MQ
TITLE: AB CMS UNIVERSE
SELECTION CRITERIA:
REGN ME 0 6
PCDS NB
STTE ME 35
CNTY ME 001
CMSC NB
OUTPUT ELEMENTS:
scsc
o
o
rH
PNME
O
O
DCL1
2 . 0
CMSC
1.0
CMSD
25 . 0
CMS I
1.0
SFD1
8 . 0
SORTING ELEMENTS:
CMSC A
PNME A
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
AIRS FACILITY SUBSYSTEM QUICK LOOK REPORT
AB CMS UNIVERSE
DATE: 01/08/02 SENSITIVE AMD DRAFT SIP DATA INCLUDED PAGE: 2
scsc
PNME
DCL1
CMSC
CMSD
CMS I
SFD1
3500100005
AMERICAN GYPSUM COMPANY
A
A
TITLE
V
MAJOR
2
20010621
3500100144
CITY OF ALBUQUERQUE CERRO COLORADO LANDF
A
A
TITLE
V
MAJOR
2
20000922
3500100145
CITY OF ALBUQUERQUE SOUTHSIDE RECLAMATIO
A
A
TITLE
V
MAJOR
2
20010108
3500100368
DELTA-PERSON GENERATING PROJECT
A
A
TITLE
V
MAJOR
2
20010129
3500100024
DEPT OF ENERGY SANDIA NATIONAL LABS
A
A
TITLE
V
MAJOR
2
20001009
3500100143
EARTHGRAIN S
A
A
TITLE
V
MAJOR
2
20010501
3500100026
KIRTLAND AIR FORCE BASE
A
A
TITLE
V
MAJOR
2
20000801
3500100011
PNM/REEVES GENERATING STATION
A
A
TITLE
V
MAJOR
2
20010221
3500100008
RIO GRANDE PORTLAND CEMENT
A
A
TITLE
V
MAJOR
2
20000622
3500100402
THOMAS & BETTS
A
A
TITLE
V
MAJOR
2
19990811
3500100141
UNIVERSITY OF NEW MEXICO
A
A
TITLE
V
MAJOR
2
20000912
3500100041
VULCAN MATERIALS COMPANY
A
A
TITLE
V
MAJOR
2
20010411
3500100197
ALBUQUERQUE PUBLISHING
SM
S
80%
SYNTHETIC
MINOR
5
3500100033
CHEVRON USA PRODUCTS COMPANY
SM
S
80%
SYNTHETIC
MINOR
5
20000509
3500100032
CONOCO INC
SM
S
80%
SYNTHETIC
MINOR
5
19980402
3500100201
CRESCENT REAL ESTATE/ALBUQUERQUE PLAZA
SM
S
80%
SYNTHETIC
MINOR
5
20010823
3500100108
FEDERAL AVIATION ADMINISTRATION FAA
SM
S
80%
SYNTHETIC
MINOR
5
19990914
3500100031
GIANT MID-CONTINENT
SM
S
80%
SYNTHETIC
MINOR
5
20010809
3500100101
LAFARGE CORP CHAPPELL RD
SM
S
80%
SYNTHETIC
MINOR
5
20010416
3500100097
LOVELACE MEDICAL CENTER
SM
S
80%
SYNTHETIC
MINOR
5
20000907
3500100084
PHILIPS SEMICONDUCTORS
SM
S
80%
SYNTHETIC
MINOR
5
20010214
3500100029
PHILLIPS PIPELINE COMPANY
SM
S
80%
SYNTHETIC
MINOR
5
20010628
3500100146
PREMIER INDUSTRIES
SM
S
80%
SYNTHETIC
MINOR
5
3500100052
PRESBYTERIAN HOSPITAL
SM
S
80%
SYNTHETIC
MINOR
5
20010518
3500100156
QWEST
SM
S
80%
SYNTHETIC
MINOR
5
20000728
3500100030
SHAMROCK LOGISTICS OPERATIONS LP
SM
S
80%
SYNTHETIC
MINOR
5
20010706
3500100142
ST. JOSEPH MECICAL CENTER
SM
S
80%
SYNTHETIC
MINOR
5
20000907
3500100157
VETERAN'S ADMINISTRATION HOSPITAL
SM
S
80%
SYNTHETIC
MINOR
5
20010207
3500100082
WAYCOR REDI MIX INC.
SM
S
80%
SYNTHETIC
MINOR
5
20000726
TOTAL NUMBER OF LINES:
29
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GENERAL REPORT INFORMATION:
USER ID: MUX
REPORT NAME: AB022
FORMAT TYPE: MQ
TITLE: AB CMS UNIVERSE
SELECTION CRITERIA:
REGN ME 0 6
PCDS NB
STTE ME 35
CNTY ME 001
CMSC NB
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
CMSD
CNTY
HEADINGS FOR COLUMNS:
001
SORTING ELEMENTS:
CMSC A
PNME A
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
-------
DATE: 01/08/02
AIRS FACILITY SUBSYSTEM QUICK LOOK MILESTONE REPORT
AB CMS UNIVERSE
SENSITIVE AMD DRAFT SIP DATA INCLUDED
PAGE:
2
ALL DATA
CNTY
CMSD TOTAL 001
TITLE V MAJOR 12 12
8 0% SYNTHETIC MINOR 17 17
29 29
# ITEMS: 2
-------
GENERAL REPORT INFORMATION:
USER ID:
REPORT NAME:
FORMAT TYPE:
TITLE:
MUX
ABO 2 3
Ml
AB FY02
STATE CONDUCTED FULL COMPLIANCE EVALUATIONS FCE
COMMENTS:
ONLY INCLUDES OPST EQUAL O, T, AMD I IN THE OUTPUT.
COVERAGE ONLY
SUPRESSES DUPLICATE COUNT OF AIR PROGRAM CODE OR MULTIPLE
INSPECTIONS IN ONE YEAR
SELECTION CRITERIA:
REGN
ME
06
STTE
ME
35
CNTY
ME
001
PCDS
NB
OPST
CE
0
OPST
CE
T
OPST
CE
I
ANT1
CE
FS
ANT1
CE
FF
DTA1
GE
011001
DTA1
LE
011231
APC1
NE
3
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
CNTY
DCL1
HEADINGS FOR COLUMNS:
A
SM
B
C
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
END OF REPORT
-------
GENERAL REPORT INFORMATION:
USER ID:
REPORT NAME:
FORMAT TYPE:
TITLE:
MUX
ABO 2 4
Ml
AB FY02
STATE CONDUCTED PARTIAL COMPLIANCE EVALUATIONS PCE
COMMENTS:
ONLY INCLUDES OPST EQUAL O, T, AMD I IN THE OUTPUT.
COVERAGE ONLY
SUPRESSES DUPLICATE COUNT OF AIR PROGRAM CODE OR MULTIPLE
INSPECTIONS IN ONE YEAR
SELECTION CRITERIA:
REGN
ME
06
STTE
ME
35
CNTY
ME
001
PCDS
NB
OPST
CE
0
OPST
CE
T
OPST
CE
I
ANT1
CE
PS
ANT1
CE
PX
DTA1
GE
011001
DTA1
LE
011231
APC1
NE
3
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
CNTY
DCL1
HEADINGS FOR COLUMNS:
A
SM
B
C
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
END OF REPORT
-------
GENERAL REPORT INFORMATION:
USER ID: MUX
REPORT NAME: AB0210B
FORMAT TYPE: Q1
TITLE: AB FY02 STATE CONDUCTED STACK TESTS DETAIL
COMMENTS:
ONLY INCLUDES OPST EQUAL O, T, AMD I IN THE OUTPUT.
SELECTION CRITERIA:
REGN
ME
06
STTE
ME
35
CNTY
ME
001
PCDS
NB
OPST
CE
0
OPST
CE
T
OPST
CE
I
ANT1
CE
6C
ANT1
CE
3A
ANT1
CE
TR
DTA1
GE
011001
DTA1
LE
011231
APC1
NE
3
OUTPUT ELEMENTS:
SCSC
o
o
rH
PNME
O
O
ACS 1
1.0
ATP1
2 . 0
ADL1
Cn
o
o
DTA1
6.0
RSC1
2 . 0
PLC1
5 . 0
PASS/OR/FAIL
PLLT//
SORTING ELEMENTS:
RSC1 A
PNME A
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
GENERAL REPORT INFORMATION:
USER ID:
REPORT NAME:
FORMAT TYPE:
TITLE:
MUX
ABO 2 5
Ml
AB FY02
STATE CONDUCTED INVESTIGATIONS
COMMENTS:
ONLY INCLUDES OPST EQUAL O, T, AMD I IN THE OUTPUT.
COVERAGE ONLY
SUPRESSES DUPLICATE COUNT OF AIR PROGRAM CODE OR MULTIPLE
INSPECTIONS IN ONE YEAR
SELECTION CRITERIA:
REGN
ME
06
STTE
ME
35
CNTY
ME
001
PCDS
NB
OPST
CE
0
OPST
CE
T
OPST
CE
I
ANT1
CE
SI
ANT1
CE
SE
DTA1
GE
011001
DTA1
LE
011231
APC1
NE
3
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
CNTY
DCL1
HEADINGS FOR COLUMNS:
A
SM
B
C
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
END OF REPORT
-------
GENERAL REPORT INFORMATION:
USER ID:
REPORT NAME:
FORMAT TYPE:
TITLE:
MUX
ABO2 6
QB
AB STATE ENFORCEMENT ACTIONS FOR FY02
COMMENTS:
RECAP CRITERIA ST-ACS
ADDS NOVS, CONSENT AGREEMENTS EXECUTED
ADDS TITLE V COMPLIANCE CERTIFICATION STATE REVIEW
MAJORS ONLY
SELECTION CRITERIA:
REGN
ME
06
PCDS
NB
STTE
ME
35
CNTY
ME
001
DCL1
CE
A
DCL1
CE
SM
APC1
NE
3
OPST
CE
0
OPST
CE
T
OPST
CE
I
DTA1
GE
011001
DTA1
LE
011231
ANT1
CE
7C
ANT1
CE
8C
ANT1
CE
9C
ANT1
CE
IE
ANT1
CE
8C
ANT1
CE
2D
ANT1
CE
ID
ANT1
CE
2K
ANT1
CE
2E
OUTPUT ELEMENTS:
SCSC
o
o
rH
STRS
Cn
o
PNME
o
o
APC1
1.0
ADL1
25 . 0
DTA1
6.0
PAM1
7 . 0
DCL1
2 . 0
SORTING ELEMENTS:
ADL1 A
PNME A
JCL PARAMETERS:
-------
ACCOUNT CODE:
FIMAS ID:
TIME (MIN,SEC):
PRIORITY CODE:
MESSAGE CLASS:
NUMBER OF COPIES
FORM NUMBER:
ROOM/BIN NUMBER:
HOLDING OUTPUT?
PRINTER SITE ID:
OUTPUT FILES:
AIR6
AFSCP
5 0
2
A
1
6PDS
Y
R2 55
-------
GENERAL REPORT INFORMATION:
USER ID: MUX
REPORT NAME: AB02 7
FORMAT TYPE: QB
TITLE: AB TITLE V ANNUAL COMPLIANCE CERTIFICATIONS
COMMENTS:
REVIEWED DURING FY02
SELECTION CRITERIA:
REGN
ME
06
PCDS
NB
STTE
ME
35
CNTY
ME
001
DTA1
GE
011001
ANT1
CE
ER
ANT1
CE
SR
ANT1
CE
CC
OUTPUT ELEMENTS:
SCSC
o
o
rH
PNME
O
O
ANT1
2 . 0
ADL1
o
o
APC1
1.0
AIR/PROG/CODE
DTS1
6.0
DATE/SCHED/
DTA1
6.0
DATE / ACHVD /
RSC1
2 . 0
RESULTS/CODE/
RD81
2 . 0
DEV//
SORTING ELEMENTS:
ADL1 A
PNME A
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
GENERAL REPORT INFORMATION:
USER ID: MUX
REPORT NAME: ABO2PERM
FORMAT TYPE: Ml
TITLE: EVENTS FOR OPERATING PERMIT TRACKING IN ALBUQUERQUE
SELECTION CRITERIA:
REGN ME 0 6
PCDS NB
STTE ME 35
CNTY ME 001
PATY NB
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
PADL
DCL1
HEADINGS FOR COLUMNS:
A
SM
B
C
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
DATE: 01/08/02
AIRS FACILITY SUBSYSTEM QUICK LOOK MILESTONE REPORT
EVENTS FOR OPERATING PERMIT TRACKING IN ALBUQUERQUE
SENSITIVE AMD DRAFT SIP DATA INCLUDED
PAGE:
2
ALL DATA
DCL1 DCL1 DCL1 DCL1
PADL TOTAL A SM B C
*PA PREPARES DRAFT PERMIT
15
6
9
0
*PERMIT AUTHORITY ISSUES FINAL PERMIT
11
6
5
0
^PROPOSED PERMIT RECEIVED BY EPA
10
6
4
0
AFFECTED AGENCY RECEIVES DRAFT PERMIT FOR REVIEW
1
0
1
0
AGENCY NOTIFIED OF DRAFT PERMIT AVAILABILITY
11
1
10
0
APP REC'D - INITIAL, RENEWALS, MAJOR & MINOR MODS
34
15
13
5
APPLICATION COMPLETE BY DEFAULT
1
1
0
0
APPLICATION DETERMINED COMPLETE
19
7
9
2
APPLICATION DETERMINED TO NOT BE REQUIRED
1
0
0
1
APPLICATION INCOMPLETE
21
5
11
4
NOTIFICATION TO EPA OF PROPOSED PERMIT
1
1
0
0
PERMIT AUTHORITY NOTIFIES PUBLIC OF DRAFT PERMIT
6
1
5
0
PUBLIC REVIEW PERIOD ENDS
1
1
0
0
132 50 67 12
0
0
0
0
0
1
0
1
0
1
0
0
0
3
# ITEMS:
13
-------
GENERAL REPORT INFORMATION:
USER ID:
REPORT NAME:
FORMAT TYPE:
TITLE:
MUX
AB 02 3 CMS
Ml
AB FY02 STATE CONDUCTED FULL COMPLIANCE EVALUATIONS FCE
COMMENTS:
ONLY INCLUDES OPST EQUAL O, T, AMD I IN THE OUTPUT.
COVERAGE ONLY
SUPRESSES DUPLICATE COUNT OF AIR PROGRAM CODE OR MULTIPLE
INSPECTIONS IN ONE YEAR
SELECTION CRITERIA:
REGN
ME
06
STTE
ME
35
CNTY
ME
001
CMSC
NB
OPST
CE
0
OPST
CE
T
OPST
CE
I
ANT1
CE
FS
ANT1
CE
FF
DTA1
GE
011001
DTA1
LE
011231
APC1
NE
3
MILESTONE OUTPUT
ROW ELEMENT:
COLUMN ELEMENT:
SUBTOTAL ELEMENT
DATA ELEMENTS :
CMSC
DCL1
HEADINGS FOR COLUMNS:
A
SM
B
C
JCL PARAMETERS:
ACCOUNT CODE: AIR6
FIMAS ID: AFSCP
TIME (MIN,SEC): 5
PRIORITY CODE: 2
MESSAGE CLASS: A
NUMBER OF COPIES: 1
FORM NUMBER:
ROOM/BIN NUMBER: 6PDS
HOLDING OUTPUT? Y
PRINTER SITE ID: R255
OUTPUT FILES:
-------
END OF REPORT
-------
Section 4
CMS Technical Support Document
-------
This page was intentionally left blank
-------
United States
Environmental Protection Agency
Office of
Compliance (2223A)
Version 1.9
May 10, 2002
Office of Enforcement and
Compliance Assurance
The Clean Air Act
Stationary Source
Compliance Monitoring Strategy
AIRS/AFS
Technical Support Document
-------
-------
Table of Contents
TABLE OF CONTENTS
Page
INTRODUCTION Page 1
SECTION 1: CMS REPORTING Page 3
1.1 Facility Identification Page 6
1.2 Compliance Evaluation Tracking Page 6
1.3 Title V Annual Compliance Certifications Page 6
1.4 Stack Tests Page 7
1.5 Minimum Frequencies Page 8
1.6 Unknown Compliance Status Page 8
1.7 Scheduled Full Compliance Evaluations Page 9
1.8 Annual Scheduled FCE versus Completed FCE Page 9
SECTION 2: AFS ENHANCEMENTS Page 10
2.1 Default Compliance Status Page 10
2.2 Default Classification Page 10
2.3 Date of Last Inspection & Inspection Type Page 10
2.4 New Plant CMS Record Page 11
2.5 Latest Full Compliance Evaluation Date & Type Page 13
2.6 Utility to Automatically Generate Unknown Compliance Page 13
2.7 Utility to Automatically Remove Previously Generated Unknown
Compliance Page 13
2.8 Modify AFS Action Table Page 16
2.9 Modify AFS Results Code Table Page 16
2.10 Full Compliance Evaluation Pathway Page 16
2.11 Special Ad-hoc Acronym Page 17
APPENDIX A: The CMS Policy Page 18
APPENDIX B: AFS Data Dictionary Pages Page 32
APPENDIX C: Batch Transaction Layout Page 58
APPENDIX D: Additional AFS Screens Page 60
APPENDIX E: Minimum Data Requirements Page 63
Page i
-------
Table of Contents
LIST OF TABLES/FIGURES
Tables Page
Table 1-1: New AFS fields Page 4
Figures
Figure 2-1: Browse Screen 516 - Plant CMS Record Page 12
Figure 2-2: Flowchart - Generating Unknown Compliance Status Page 14
Figure 2-3: Flowchart - Removing Generated Unknown Compliance Status Page 15
Page ii
-------
INTRODUCTION
INTRODUCTION
In April 2001, the United States Environmental Protection Agency (EPA) issued
the revised Clean Air Act Stationary Source Compliance Monitoring Strategy (CMS).
The revised CMS was developed by EPA in conjunction with representatives from the
State and Territorial Air Program Administrators/Association of Local Air Pollution
Control Officials (STAPPA/ALAPCO). CMS is the Agency's national policy which forms
the basis for planning, implementing and evaluating stationary source air compliance
monitoring programs. This revised policy replaces the previous 1991 CMS and is to
take effect immediately. Therefore, fiscal year 2002 air compliance monitoring
programs should be negotiated consistent with the revised policy.
The major changes to CMS from the previous 1991 version are as follows:
(1) Emphasis has been placed on Title V major sources and a limited subset of
synthetic minor sources.
(2) Minimum frequencies have been recommended for determining the
compliance status of facilities covered by this policy. Alternatives may be
developed and negotiated with the Regions to enable States/locals to address
important local compliance issues.
(3) The policy explicitly recognizes that a variety of tools ranging from self-
certifications to traditional stack tests are available and should be used to
evaluate compliance. It further recognizes that on-site visits may not be
necessary to evaluate the compliance status of a facility given the wide range of
self-reported information such as annual Title V compliance certifications,
deviation reports, and semi-annual monitoring reports based on periodic
monitoring and compliance assurance monitoring. However, to ensure a
compliance presence in the field, a minimum frequency for on-site visits has
been recommended.
(4) Three categories of compliance monitoring replace the current levels of
inspection. The new compliance monitoring categories are: Full Compliance
Evaluations, Partial Compliance Evaluations, and Investigations.
(5) CMS plans are no longer required to be submitted every year, but may be
submitted once every two years.
To facilitate implementation of the revised CMS in FY 2002, changes are
Page 1
-------
INTRODUCTION
currently being made to the Aerometric Information Retrieval System/AIRS Facility
Subsystem (AIRS/AFS) and are being incorporated in the Information Collection
Request, "Source Compliance and State Action Reporting," OMB Number 2060-0391.
AIRS/AFS is the national compliance and enforcement data system for stationary
sources of air pollution and serves as a repository for access to EPA as well as
State/local compliance monitoring data. Specifically, changes are being made to
AIRS/AFS to provide for additional collection activities associated with identifying
facilities; conducting compliance evaluations; and the input of information on Title V
compliance certifications and stack tests. Changes to the system are scheduled to be
completed by the end of this fiscal year. To the extent that AIRS/AFS is replaced by
another system, these changes also will apply to its successor.
The purpose of this technical support document is to explain the changes that
are being made to AIRS/AFS to accommodate the revised CMS, and to provide
detailed information on the specific system enhancements and new AFS fields. As part
of an ongoing effort to work with the States and locals in implementing this policy, EPA
is providing training in each Regional office on the overall policy, as well as the
resulting changes in AIRS/AFS.
Page 2
-------
SECTION 1: CMS REPORTING
SECTION 1: CMS REPORTING
Changes have been made in the national air compliance data system
(AIRS/AFS) to facilitate the reporting of information consistent with the revised structure
of this policy. In addition, the Source Compliance and State Action Reporting ICR have
been revised to incorporate the new data elements.
In order to collect compliance information in a format that allows EPA to evaluate
and compare compliance monitoring programs, Regions and States/locals will need to:
Continue to maintain records of compliance monitoring activities, and on a
routine basis, report these activities and the results in AIRS/AFS, or its
successor
Continue to designate the High Priority Violation (HPV) status of violating
facilities in accordance with the EPA HPV Policy dated December 22, 1998
Report Full Compliance Evaluations (FCE), Partial Compliance Evaluations
(PCE) and Investigations at the facility level in AIRS/AFS, or its successor
Report Title V annual compliance certification reviews
Report all stack tests
The following subsections summarize the CMS reporting with regard to AFS and
describe how AFS accommodates these needs.
Table 1-1 is a listing of new AFS fields and their properties and will be further
elaborated on in the following sections.
Page 3
-------
SECTION 1: CMS REPORTING
Table 1-1: New AFS fields
Data Element
Name
AFS
Acronym
Format
Length
Required
Valid Values
Security
File
Location
Screen
Number
Batch
Trans & seq #
CMS Source
Category
CMSC
alpha
1
No
A, M&S
Update - limited by special access
code
Read - public
Plant CMS
Update -315
Browse - 516
Transaction 18
Sequence 1
column 14
CMS Source
Category
Description
CMSD
alpha
20
generated
from
descriptions
in Table File
A=Title V Major
M=Mega-site
S=80%SM
Update -N/A
Read - Public
Plant CMS
Update - N/A
Browse - 516
N/A
CMS
Minimum
Frequency
Indicator
CMSI
alpha
1
No
1-9
Update - limited by special access
code
Read - Sensitive
Plant CMS
Update -315
Browse - 516
Transaction 18
Sequence 1
Column 15
Fiscal Year of
FC E
CMYA -
CMYE
alpha
4
No
numerics >= 2002
Update - limited by special access
code
Read - Sensitive
Plant CMS
Update -315
Browse - 516
Transaction 18
Sequence 1
Columns 16-19,
21-24, 26-29, 31-
34 & 36-39
On-Site Visit
Indicator
CMOA -
CMOE
alpha
1
No
Y = Yes
N = No
Update - limited by special access
code
Read - Sensitive
Plant CMS
Update -315
Browse - 516
Transaction 18
Sequence 1
Columns 20, 25,
30, 35 & 40
State FCE
Type
SFT1
alpha
2
generated
from plant
actions
N/A
None
Plant CMS
Update - N/A
Browse - 516
N/A
State FCE
Date
SFD1
alpha
8
generated
from plant
actions
generated in
YYYYMMDD format
None
Plant CMS
Update - N/A
Browse - 516
N/A
Page 4
-------
SECTION 1: CMS REPORTING
Table 1-1 (continued): New AFS fields
Data
Element
Name
AFS
Acronym
Format
Length
Required
Valid Values
Security
File
Location
Screen
Number
EPA FCE
Type
EFT1
alpha
2
generated
from plant
actions
N/A
None
Plant CMS
Update - N/A
Browse - 516
N/A
EPA FCE
Date
EFD1
alpha
8
generated
from plant
actions
generated in
YYYYMMDD
format
None
Plant CMS
Update - N/A
Browse - 516
N/A
Default
FCE Type
DFT1
alpha
2
generated
using EFT1
& SFT1
N/A
None
Plant CMS
Update - N/A
Browse - 516
N/A
Default
FCE Date
DFD1
alpha
8
generated
from plant
actions
generated in
YYYYMMDD
format
None
Plant CMS
Update - N/A
Browse - 516
N/A
CMS
Comment
CM19
alpha
39
No
no validation
Update - limited by special access
code
Read - Sensitive
Plant CMS
Update -315
Browse - 516
Transaction 18
Sequence 1
Columns 41 -79
Date
Record is
Last
Updated
DU19
alpha
6
generated
YYMMDD
None
Plant CMS
N/A
N/A
Person
Updating
Record
PU19
alpha
3
generated
Any NCC User ID
None
Plant CMS
N/A
N/A
Special
Ad-hoc
filtering
acronym
CM FY
N/A
4
No
N/A
N/A
N/A
N/A
N/A
Page 5
-------
SECTION 1: CMS REPORTING
1.1 Facility Identification
Identify Title V major sources (including mega-sites) and SM sources at or above
80% of Title V potential to emit threshold (80%SM).
AFS Modification:
Major sources are already identified in AFS through the use of classification
code fields (SCL1 & ECL1). Majors and 80% SM's will be further identified in AFS
through the use of a new field known as the CMS Source Category (CMSC).
CMS Source Category was initially populated in AFS using the default plant
classification value (DCL1). New plants and exceptions to the CMS will be manually
input by the Region unless otherwise negotiated with States and Local agencies.
1.2 Compliance Evaluation Tracking
Support the tracking of FCE's, PCE's and Investigations through the addition of
regional action types: Complete Review of All Required Reports including Title V
Annual Compliance Certifications; Assessment of Control Device and Process
Operating Conditions; Visible Emissions Observation Performed; Review of Facility
Records and Operating Logs; Assessment of Process Parameters; Assessment of
Control Equipment Performance Parameters; and Stack Tests
AFS Modification:
Regional action types with links to appropriate national action types have been
added to AFS Action tables. Modifications to existing Regional action types will be
made if necessary.
1.3 Title V Annual Compliance Certifications
The following information will need to be entered into AIRS/AFS regarding Title
V Annual Compliance Certifications received and reviewed.
Unless otherwise negotiated with States and local agencies, Regions shall enter
date due, date received and whether deviations were reported. Regions, States and
locals will be responsible for entering date reviewed and results for the annual
compliance certifications each of them reviewed.
Date due - The anniversary date of the annual compliance certification. It can
Page 6
-------
SECTION 1: CMS REPORTING
be derived using permit data previously recorded in AFS and should be
recorded as the date scheduled on a Title V Annual Compliance Certification
Received' action record.
Date received - The date the annual compliance certification was received by
the Region. This should be recorded as the date achieved on a Title V Annual
Compliance Certification Received' action record.
Deviations - A Y/N indicator will be used to report whether deviations were
reported in the annual compliance certification review (Y=deviations were
reported, or N=deviations were not reported). This indicator will be recorded in
the RD81 (Regional Data Element 8) field on a Title V Annual Compliance
Certification Reviewed' action record. Details of the deviation may be entered
as action comments.
Date Reviewed - This is the date the annual compliance certification was
reviewed. The review might be performed by a Region, State or local agency.
The review date will be recorded as the date achieved on a Title V Annual
Compliance Certification Reviewed' action record.
Results - The results of an annual compliance certification review will be
recorded in the results code field on a Title V Annual Compliance Certification
Reviewed' action record. Codes that identify "In compliance", "In Violation" or
"Unknown" will be available. When evaluation of a self certification leads to a
determination of non-compliance and/or HPV status, then this finding should be
documented in the appropriate AIRS/AFS fields.
1.4 Stack Tests
Support tracking of the performance of all stack tests.
AFS Modification:
AFS already supports the recording of stack tests through the use of actions.
The date and results data related to the stack test will need to be entered into AFS.
Additionally, if a violation is found as a result of the stack test, then appropriate
violation data will also be entered into AFS.
Date - The date the stack test was performed should be recorded in the Date
achieved field of an action record
Page 7
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SECTION 1: CMS REPORTING
Results - The conclusion of all stack tests should be recorded in the results code
field of an action record. Codes representing "Pass" or "Fail" will be used by the
Region, State or local agency.
Pollutant - The pollutant related to the conducted stack test may be recorded in
the pollutant field of an action.
1.5 Minimum Frequencies
Indicate the minimum frequency of an FCE.
AFS Modification:
The minimum frequency of an FCE will be identified in a new field referred to as
the CMS Minimum Frequency Indicator (CMSI). This will represent the number of
years allowable between FCE's. CMSI has been initially populated in AFS using the
CMS Source Category (CMSC). New plants and exceptions to the CMS will be
manually input by the region unless otherwise negotiated with States and Local
agencies. This field is enforcement sensitive.
1.6 Unknown Compliance Status
Automatically change the Federal compliance status (ECAP) of a facility to
'unknown by evaluation calculation' if an FCE is not completed in accordance with the
CMS Minimum Frequency Indicator (CMSI).
AFS Modification:
An AFS utility that reads the CMS Minimum Frequency Indicator (CMSI), current
system date and the EPA/State Date of Last FCE (DFD1) has been developed. Plants
that do not maintain FCE action types with a date achieved that falls within the CMSI
time frame will have their Federal Compliance Status Code (ECAP) automatically
changed to 'unknown by evaluation calculation' using pollutant FACIL (PLAP). PLAP
and ECAP are located on the Air Program pollutant record. The Title V air program
(ACS1) will be used for Major sources (including Mega sites) and the FESOP or SIP air
program (ACS1) will be used for 80%SM sources. Additionally, the utility will
'ungenerate' the 'unknown' status when an FCE has been recorded against the plant.
Page 8
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SECTION 1: CMS REPORTING
1.7 Scheduled Full Compliance Evaluations
Support the ability to determine which plants have been scheduled for a FCE for
a given fiscal year and if an on-site visit is planned for that year.
AFS Modification:
The fiscal year of the scheduled FCE will be indicated in AFS through the use of
year fields known as Fiscal Year of FCE. These are new fields in AFS and will be
available to indicate CMS plans for a 5 year period (CMYA-CMYE). Each year field
will have an on-site indicator (CMOA-CMOE) identifying whether an on-site visit is
planned for that fiscal year.
Although States/Locals, as part of the CMS biennial plan, submit a list of
facilities that are scheduled for an FCE in a given fiscal year, the use of these data
fields in AFS is optional.
1.8 Annual Scheduled FCE versus Completed FCE
Support the ability to determine which plants have been scheduled for an FCE
for a given fiscal year and did not receive one (either no FCE or an FCE outside the FY
it was scheduled).
AFS Modification:
Existing AFS Ad-hoc procedures can be used to determine those plants
scheduled for an FCE in a given year and actually received one. A new Ad-hoc
acronym (CMFY) has been developed to determine those plants which were scheduled
for an FCE but did not have one performed.
Page 9
-------
SECTION 2: AFS ENHANCEMENTS
SECTION 2: AFS ENHANCEMENTS
This section describes AFS enhancements that have been made for
implementing CMS into AFS.
2.1 Default Compliance Status
Compliance status is available on numerous AFS records: Plant General, Air
Program, Air Program Pollutant, Plant History, Point Air Program and Point History. On
each of these records, compliance status is stored in two separate fields, one for State
and another for EPA. In addition to State and EPA compliance status, a default
compliance status is available. Default compliance status returns the EPA value, but if
that is blank, then the State value is returned. Additional information on the various
compliance status fields can be found in the Data Dictionary pages in Appendix B of
this document.
AFS has been modified so that the default compliance status returns the most
"out of compliance" value without priority to either State or EPA. This modification does
not effect data input, but rather produces a widely called for correction in data output.
2.2 Default Classification
Classification is available on three AFS records: Plant General, Plant Air
Program and Plant Air Program Pollutant. On each of these records, classification is
stored in two separate fields, one for State and another for EPA. In addition to State
and EPA classification values, default classification is available. Default classification
returns the EPA value, but if that is blank, then the State value is returned.
AFS has been modified so that the default classification returns the largest
classification without priority to either State or EPA. This modification does not effect
data input, but rather produces a widely called for correction in data output.
2.3 Date of Last Inspection & Inspection Type
Three categories of compliance monitoring have replaced the previous levels of
inspections. Previous to CMS, AFS maintained plant level fields for the date and type
of the latest EPA and State inspections (EID1, EDT1, SID1, SIT1). These were
generated from user inspection data. Default values (DID1 & DIT1) at plant level,
returned EPA values. These fields have become obsolete with the revised CMS and
Page 10
-------
SECTION 2: AFS ENHANCEMENTS
AFS has been modified as follows:
Removal of EPA and State inspection fields (EID1, EIT1, SID1 & SIT1) from the
plant general record and browse screen 500
Removal of EID1, EIT1, SID1 &SIT1 from Fixed format 627 report
Disabled ad-hoc acronyms EID1, EIT1, SID1, SIT1, DID1 & DIT1
Disabled generation of Date of last inspection fields in Browse
Additionally, AFS maintained point level fields for the date and type of the latest
point level EPA and State inspections (EID3, EIT3, SID3, SIT3). These were generated
from user input inspection data at the point level. Default values (DID3 & DIT3) at point
level returned EPA values. The point level fields gave been modified as follows:
Renamed fields to identify date and type of latest FCE instead of Inspection
Generated from FCE data rather than inspection data
Renamed acronyms EID3, EIT3, SID3, SIT3, DID3 & DIT3 to
EFD3, EFT3, SFD3, SFT3, DFD3 & DFT3 respectively
2.4 New Plant CMS Record
A new record known as Plant CMS has been created in AFS. It will provide easy
access to all the CMS related fields and all data entry relating to CMS planning can be
performed on one screen. The 19 new fields located on this record are:
CMS Source Category (CMSC)
CMS Minimum Frequency Indicator (CMSI)
5 year fields (CMYA, CMYB, CMYC, CMYD CMYE)
On-site visit Indicator for each year field (CMOA, CMOB, CMOC, CMOD &
CMOE)
39 character comment field (CM19)
Date and type of latest EPA FCE (EFD1, EFT1)
Date and type of latest State FCE (SFD1, SFT1)
Date Record is Updated (DU19)
Person Updating Record (PU19)
The CMS Source Category (CMSC) was initially populated in AFS using the
default plant classification value (DCL1). Upon agreement with Regional data
managers, the following values will be added. Where DCL1 = A or A1, CMSC will be
populated with a 'A'. Likewise, where DCL1=SM, CMSC will be populated with a 'S'.
New plants and exceptions to the CMS will be manually input by the Region unless
Page 11
-------
SECTION 2: AFS ENHANCEMENTS
otherwise negotiated with States and Local agencies.
The CMS Minimum Frequency Indicator (CMSI) was initially populated in AFS
using the CMS Source Category (CMSC). Upon agreement with Regional data
managers, the following values will be added. Where CMSC=A, CMSI will be
populated with a '2'. If CMSC=S, CMSI will be populated with a '5'. New plants and
exceptions to the CMS will be manually input by the Region unless otherwise
negotiated with States and Local agencies.
Each of the 5 year fields has an on-site visit indicator. When a year is provided
in any of the 5 year fields, the on-site indicator will default to 'Y\
Updates to the CMS record can be done either online (screen 315) or batch
(transaction 18) and browsed on screen 516. Update authority will be restricted by a
special access code 'S' and read access is enforcement sensitive. Figure 2-1 provides
a Browse view of the new record. Appendix C describes the layout of the batch
transaction fields and additional AFS screens are available in Appendix D.
Figure 2-1: Browse Screen 516 - Plant CMS Record
DATE : 09/20/01 AIRS FACILITY SUBSYSTEM - BROWSE PGM: AFP516
SCREEN: 516 COMPLIANCE MONITORING STRATEGY MAP: AFM5161
10000 TEST PLANT 123 TEST DRIVE
( 2001/09/20 - KGJ )
CMS SOURCE CATEGORY: A - TITLE V MAJOR
CMS MINIMUM FREQUENCY INDICATOR: 2
PLANNED YEAR (S) OF FULL COMPLIANCE EVALUATION (FCE) :
FISCAL
YEAR
A
ON-SITE
VISIT
PLANNED
(Y/N)
FISCAL
YEAR
B
2004
ON-SITE
VISIT
PLANNED
(Y/N)
Y
FISCAL
YEAR
C
2006
ON-SITE
VISIT
PLANNED
(Y/N)
N
FISCAL
YEAR
D
2008
ON-SITE
VISIT
PLANNED
(Y/N)
Y
FISCAL
YEAR
E
2010
ON-SITE
VISIT
PLANNED
(Y/N)
N
COMMENT: SAMPLE COMMENT TEXT
LATEST STATE FCE ACTION: E2 DATE (YYYYMMDD): 20010515
LATEST EPA FCE ACTION : M9 DATE (YYYYMMDD): 20010415
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF10=SCRN SCREEN:
Page 12
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SECTION 2: AFS ENHANCEMENTS
2.5 Latest Full Compliance Evaluation Date & Type
New AFS fields have been created to replace the obsolete date and type of the
most recent EPA and State inspections. These fields will provide the date and type of
the most recent EPA (EFD1/EFT1) and State (SFD1/SFT1) FCE. They will be
generated from user supplied action data. Default values (DFD1/DFT1) for these fields
will be the latest date of either EPA or State FCE. The new fields are located on the
new Plant CMS record. Refer to Figure 2-1.
2.6 Utility to Automatically Generate Unknown Compliance
If it is determined that the latest FCE is not within the CMS Minimum Frequency
(CMSI) and the default compliance status (DCS1) of the plant is not out of compliance1
or unknown2, then the EPA Compliance Status (ECAP) will be changed to "U"
(Unknown by evaluation calculation). If the plant is already out of compliance or
unknown with regard to compliance status, no compliance status values will be
generated since nothing will be gained by creating another unknown compliance status.
This utility is part of the nightly AFS central batch update process. Whenever a
central update is run, the logic to generate an unknown compliance status will be
executed. Figure 2-2 shows a flowchart of the generation logic.
2.7 Utility to Automatically Remove Previously Generated Unknown
Compliance
When it is determined that the latest FCE is within the CMS Minimum Frequency
(CMSI) and the default compliance status (DCS1) of the plant is 'unknown by
evaluation calculation', the previously generated records or compliance status values
will be removed.
This utility is part of the nightly AFS central batch update process. Whenever a
central update is run, the logic to "ungenerate" an unknown compliance status will be
executed. Figure 2-3 shows a flowchart of the "ungenerate" logic.
1 Out of Compliance values are B, 1, 6 & W
2Unknown compliance status values are Y, 0, A, 7 & U
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SECTION 2: AFS ENHANCEMENTS
Figure 2-2: Flowchart - Generating Unknown Compliance Status
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SECTION 2: AFS ENHANCEMENTS
Figure 2-3: Flowchart - Removing a Previously Generated Unknown Compliance Status
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SECTION 2: AFS ENHANCEMENTS
2.8 Modify AFS Action Table
The AFS action table has been modified to include new Regional action codes
with associated national action types.
FCE with on-site visit
FCE without on-site visit
PCE's with on-site visit
PCE's without on-site visit
Investigations
Stack Tests
Title V Annual Compliance Certification Reviews
2.9 Modify AFS Results Code Table
The AFS Results code table has been modified to include new codes to record
the results of stack tests and Title V Annual Certification reviews.
New codes for Title V Annual Certification Reviews include:
In Compliance
In Violation
Unknown
New codes for the results of Stack Tests include:
Pass
Fail
2.10 Full Compliance Evaluation Pathway
A new action linking pathway to track the progress of an FCE will be included in
AFS. This pathway will be available for record keeping purposes only and is optional.
Once the "FCE" pathway is initiated, no special action types such as addressing or
resolution action types will be required and the pathway will not intrude on any other
pathway. The Pathway Summary report, FF620 will be modified to include the FCE
pathway in the selection criteria.
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SECTION 2: AFS ENHANCEMENTS
2.11 Special Ad-hoc Acronym
A new Ad-hoc acronym (CMFY) has been developed to determine those plants
that were scheduled for an FCE but did not have one performed. This includes
facilities that did not have an FCE performed at all and the ones that had one
performed outside the fiscal year it was scheduled. Currently, AFS ad-hoc would not
accomodate this type of criteria because of the date range necessary to capture all
sources that fit into this universe.
This filtering device available only in Ad-hoc, will be used as selection criteria to
indicate the desired fiscal year of the scheduled FCE. In the following example, an
AFS ad-hoc selection criteria demonstrates the need for such an acronym.
Consider the fact that five, separate year fields will be available to record the fiscal
year of a scheduled FCE. Also
consider that the default Date of
latest FCE will indicate when the
last FCE was performed, and that
the selection criteria will need to
include dates before the desired
fiscal year and dates after the
desired fiscal year so that all eligible
sources are retrieved. The chart to
the right shows selection criteria for
an ad-hoc that might list all sources
in a given geographic area (region
or state) scheduled for an FCE in
FY200, but did not have one
performed. The resulting ad-hoc
report would produce unsuccessful
results.
The new acronym (CMFY) will act
as a filtering device to: 1) locate
the facilities that are scheduled for
an FCE in a given fiscal year; and
2) did not have one performed.
Refer to the chart on the right to
see how the new acronym would
be used and notice how it
compares to the previous chart.
Acronym
Condition
Value
STTE
ME
XX
CMYA
CE
2000
CMYB
CE
2000
CMYC
CE
2000
CMYD
CE
2000
CMYE
CE
2000
DFD1
LE
990930
DFD1
GE
001001
Acronym
Condition
Value
STTE
ME
XX
CMFY
CE
2000
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APPENDIX A: CMS POLICY
APPENDIX A:
The Clean Air Act Stationary Source
Compliance Monitoring Strategy (CMS)
April 2001
DISCLAIMER
The discussion in this document is intended solely as
guidance. This document is not a regulation. It does not impose
legally binding requirements on EPA, States, or the regulated
community. This policy does not confer legal rights or impose
legal obligations upon any member of the public. The general
description provided here may not apply to a particular situation
based on the circumstances. Interested parties are free to raise
questions and objections about the substance of this policy and
the appropriateness of the application of this policy to a
particular situation. EPA retains the discretion to adopt
approaches on a case-by-case basis that differ from those
described in this policy where appropriate. This document may be
revised periodically without public notice. EPA welcomes public
input on this document at any time.
Any questions concerning this policy may be directed to
either Mamie Miller or Rob Lischinsky at 202-564-2300.
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APPENDIX A: CMS POLICY
CLEAN AIR ACT STATIONARY SOURCE COMPLIANCE MONITORING STRATEGY
April 2 001
I INTRODUCTION
The Clean Air Act Stationary Source Compliance Monitoring
Strategy (CMS) was last revised in 1991. In the intervening
years, the national policy was not consistently implemented
across the country by the EPA Regions and their State/local
agencies. Two major factors contributed to this situation:
(1) The policy became dated as new Clean Air Act (CAA)
programs were implemented, and the Environmental Protection
Agency (EPA) planning process changed. (2) EPA Headquarters
ceased to provide oversight of the policy on a national
level when the Agency's enforcement program was reorganized,
thus giving the impression that it was no longer necessary
to implement the policy.
A review by the EPA Office of the Inspector General
(Consolidated Report on OECA's Oversight of Regional and
State Air Enforcement Programs," E1G-AE7-03-0045-8100244,
September 25, 1998) identified this abandonment as a
fundamental problem that adversely affected the
effectiveness of the air enforcement program.
In response to the Office of Inspector General report,
the Office of Enforcement and Compliance Assurance (OECA)
made a commitment to evaluate how the policy was being
implemented, and to revise it as necessary. The Office of
Compliance was given the responsibility for satisfying
this commitment.
Between October 1998 and May 1999, interviews were
conducted with all of the EPA Regions and twenty-two States.
The purpose of these interviews was to collect baseline
information on implementation of the policy; obtain feedback
on its strengths and weaknesses; and identify any
appropriate alternatives. A report entitled *A Review of
the Compliance Monitoring Strategy" summarized the findings
of these interviews, and was issued on July 26, 1999.
A Workgroup with representatives from OECA Headquarters,
the Regions and several States was formed to review these
findings and develop a revised policy.
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APPENDIX A: CMS POLICY
The following policy is based on the recommendations of
this Workgroup; comments received during the comment period
on the draft proposals; and in-depth discussions with
representatives of the State and Territorial Air Pollution
Program Administrators and the Association of Local Air
Pollution Control Officials (STAPPA/ALAPCO).
The major differences between this policy and the 1991
version are as follows:
(1) Emphasis has been placed on Title V major sources
and a limited subset of synthetic minor sources.
(2) Minimum frequencies have been recommended for
determining the compliance status of facilities covered
by this policy. Alternatives may be developed and
negotiated with the Regions to enable States/locals to
address important local compliance issues.
(3) The policy explicitly recognizes that a variety of
tools ranging from self-certifications to traditional
stack tests are available and should be used to
evaluate compliance. It further recognizes that on-
site visits may not be necessary to evaluate the
compliance status of a facility given the wide range of
self-reported information such as annual Title V
compliance certifications, deviation reports, and semi-
annual monitoring reports based on periodic monitoring
and compliance assurance monitoring. However, to
ensure a compliance presence in the field, a minimum
frequency for on-site visits has been recommended.
(4) Three categories of compliance monitoring replace
the current levels of inspection defined in the 1987
Clean Air Act Compliance/Enforcement Guidance Manual.
The new compliance monitoring categories are: Full
Compliance Evaluations, Partial Compliance Evaluations
and Investigations.
(5) CMS plans are no longer required to be submitted
every year, but may be submitted once every two years.
II GOALS OF THE COMPLIANCE MONITORING STRATEGY
1. Provide national consistency in developing stationary
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APPENDIX A: CMS POLICY
source air compliance monitoring programs, while at the same
time provide States/locals with flexibility to address local
air pollution and compliance concerns.
2. Improve communication between States/locals and Regions
on stationary source air compliance monitoring programs, and
enhance EPA oversight of these programs.
3. Provide a framework for developing stationary source air
compliance monitoring programs that focuses on achieving
measurable environmental results.
4. Provide a mechanism for recognizing and utilizing the
wide range of tools available for evaluating and
determining compliance.
Ill OVERALL PROCESS
1. States/locals submit a CMS plan biennially for
discussion with and approval by the Regions. Regions also
prepare a plan biennially for discussion with their
States/locals.
2. The plans are summarized, and incorporated into the
annual Regional response to the OECA Memorandum of
Agreement (MOA).
3. States/locals and Regions maintain records of their
compliance monitoring activities, and enter facility-
specific compliance data in the national air compliance data
base (AIRS/AFS, or its successor).
4. States/locals and Regions review the results of the
compliance monitoring activities annually, and prepare an
annual update to the biennial plan as necessary. Major
redirections are discussed as they arise.
5. Regions conduct in-depth evaluations of the overall
State/local compliance monitoring program periodically.
Headquarters conducts similar evaluations of the Regional
programs as well.
IV SCOPE OF POLICY
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APPENDIX A: CMS POLICY
EPA recognizes that State/local agencies perform
additional compliance monitoring activities beyond those
addressed by this policy. This policy is not designed to
preclude those activities, but focuses on federally
enforceable requirements for the following source
categories: (1) Title V major sources; and (2) synthetic
minor sources that emit or have the potential to emit at or
above 80 per cent of the Title V major source threshold.
For purposes of this policy, potential to emit means the
maximum capacity of a stationary source to emit a pollutant
under its physical and operational design. Any physical or
operational limitation on the capacity of the source to emit
a pollutant, including air pollution control equipment and
restrictions on hours of operation, shall be treated as part
of its design if the limitation or the effect it would have
on emissions is federally enforceable or legally and
practicably enforceable by a state or local air pollution
control agency.
The 80 per cent threshold was selected to ensure that those
facilities that either have the potential to emit or
actually emit pollutants close to the major source threshold
are evaluated periodically. This enables States/locals to
focus resources on those facilities that are most
environmentally significant. In determining whether a
synthetic minor source falls within the scope of this
policy, all facilities with the potential to emit at or
above the 80 per cent threshold are included regardless of
whether their actual emissions are lower.
V COMPLIANCE MONITORING CATEGORIES
States/locals and Regions are encouraged to use a variety
of techniques to determine compliance, and utilize the full
range of self-monitoring information stemming from the 1990
CAA Amendments.
Consistent with this approach, there are three categories
of compliance monitoring: Full Compliance Evaluations,
Partial Compliance Evaluations, and Investigations. Each of
these categories is defined below:
1. Full Compliance Evaluations
A Full Compliance Evaluation is a comprehensive
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APPENDIX A: CMS POLICY
evaluation of the compliance status of a facility.
(For the purposes of this policy, 'facility" is used in
the broadest sense of the term incorporating all
regulated emission units within the 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
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 assess 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,
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APPENDIX A: CMS POLICY
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 data.
In addition to conducting a stack test when there
is no other means of determining compliance,
States/locals should conduct a stack test whenever
they deem appropriate.
A Full Compliance Evaluation should be completed within
the fiscal year in which the commitment is made, except
in the case of extremely large, complex facilities
(hereafter referred to as mega-sites). Regulatory
agencies may take up to three years to complete a Full
Compliance Evaluation at a mega-site, provided the
agency is conducting frequent on-site visits or Partial
Compliance Evaluations throughout the entire
evaluation period.
A Full Compliance Evaluation may be done piecemeal
through a series of Partial Compliance Evaluations.
2. Partial Compliance Evaluations
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 Partial Compliance Evaluation
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 (or up to three
years at mega-sites) to satisfy the requirements of a
Full Compliance Evaluation.
This type of evaluation could be used for example to
effectively assess compliance with the HON MACT
requirements if that is the primary area of concern at
a chemical manufacturing facility. If at some point
later in the year, the regulatory agency decided a Full
Compliance Evaluation was necessary, the agency could
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APPENDIX A: CMS POLICY
combine the results of the MACT evaluation with
subsequent evaluations focusing on the balance of other
CAA requirements.
3. Investigations
An Investigation can be distinguished from the other
two categories in that generally it 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 Full
Compliance Evaluation because of time constraints, the
type of preliminary field work required, and/or the
level of analytical expertise needed to
determine compliance.
Examples of this category of compliance monitoring are
the in-depth PSD/NSR and NSPS reviews conducted by EPA
of the pulp, utility and petroleum refining industries.
These investigations were initiated following analyses
of publicly available information on growth within the
industries, and a comparison of this information to
data maintained by the regulatory agencies on the
number of PSD/NSR permits issued during the same
timeframe. The analyses indicated that many facilities
failed to obtain the necessary permits. As a result,
the facilities had not controlled pollutant emissions
as required, and thus realized significant
economic benefits.
For a more complete definition of an Investigation, see
MOA Guidance (Air Program)-Clarification and National
Performance Measures Strategy (NPMS) Pilot" from Eric
Schaeffer and Elaine Stanley to MOA Coordinators,
Enforcement Coordinators, and RS&T Coordinators
(October 26, 1998) .
VI RECOMMENDED EVALUATION FREQUENCIES
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APPENDIX A: CMS POLICY
The following minimum frequencies are recommended:
(1) A Full Compliance Evaluation should be conducted,
at a minimum, once every two years at all Title V major
sources except those classified as mega-sites. For
mega-sites, a Full Compliance Evaluation should be
conducted, at a minimum, once every three years.
Each Region, in consultation with affected
States/locals, has the flexibility to define and
identify mega-sites as it deems appropriate within the
Region. However, this universe of facilities is
expected to be small. When identifying mega-sites, the
Regions should consider the following factors: the
number and types of emission units; the volume and
character of pollutants emitted; the number and types
of control and monitoring systems; the number of
applicable regulatory requirements; the availability of
monitoring data; the degree of difficulty in
determining compliance at individual units and at the
entire facility; and the footprint of the facility.
Examples of industries that may have qualifying
facilities are petroleum refining, integrated steel
manufacturing, chemical manufacturing, and
pharmaceutical production.
(2) A Full Compliance Evaluation should be conducted,
at a minimum, once every five years at synthetic minor
sources that emit or have the potential to emit at or
above 80 per cent of the Title V major
source threshold.
(3) An on-site visit should be conducted, at a minimum,
once every five years at all Title V major sources to
ensure a compliance presence in the field, verify
record reviews, observe modifications or new
construction, and identify any major permit deviations.
In those years when a Full Compliance Evaluation is not
conducted, States/locals should continue to review annual
compliance certifications, and the underlying reports
supporting those certifications (e.g., semi-annual and
periodic monitoring reports, continuous emission and
continuous parametric monitoring reports, and malfunction
and excess emission reports).
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APPENDIX A: CMS POLICY
VII ALTERNATIVES TO THE RECOMMENDED EVALUATION FREQUENCIES
States/locals may develop with Regional approval
alternatives to the recommended evaluation frequencies.
Alternatives may be developed on a facility-by-facility
basis, or for an entire source category. However, in
determining whether an alternative frequency is appropriate,
the following factors should be considered:
Compliance history,
Location of facility,
Potential environmental impact,
Operational practices ( e.g., whether operation is
steady state or seasonal),
Use of control equipment,
Participation in Agency-sponsored voluntary programs
(e.g., Project XL, Performance Track),
Identified deficiencies in the overall State/local
compliance monitoring program.
VIII ELEMENTS OF THE CMS PLAN
CMS plans should be submitted biennially, consistent with
the current EPA two-year MOA planning process. These plans
are a building block in the MOA process, and should be
finalized so that they can be summarized and incorporated
into the Regional MOA submissions to EPA Headquarters.
Therefore, they should be completed prior to the beginning
of the Federal fiscal year. It is not necessary to
duplicate the detailed information in the CMS plan when
submitting the Regional MOA response. Rather, Regions
should summarize and reference the CMS plans as appropriate.
A separate CMS plan is not necessary if Regions and
States/locals wish to continue using other formally
negotiated documents (e.g., Selective Enforcement
Agreements, Performance Partnership Agreements, and Grant
Agreements), provided these documents contain the same level
of detail discussed below. If this approach is selected,
the document should specifically state that it satisfies the
CMS plan.
The content of CMS plans will vary depending upon whether
States/locals develop and negotiate alternatives to the
minimum frequencies.
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APPENDIX A: CMS POLICY
In those instances where States/locals meet the
recommended minimum frequencies and do not develop and
negotiate alternative approaches, the plan should include
the following elements:
(1) A facility-specific list (including the AFS
identification numbers) of all Title V major sources.
The list should identify by fiscal year those
facilities for which a Full Compliance Evaluation will
be conducted. It should also identify those for which
an on-site visit will be conducted.
(2) A facility-specific list (including the AFS
identification numbers) of all synthetic minor sources
and a list of those facilities covered by the policy.
It also should identify by fiscal year those facilities
for which a Full Compliance Evaluation will
be conducted.
(3) A description of how a State/local will address
any identified program deficiencies in its compliance
monitoring program. These deficiencies can stem from
evaluations conducted internally, or by outside
organizations such as the EPA Office of
Inspector General.
In those instances where the States/locals propose
alternatives to the recommended minimum frequencies,
States/locals should provide a more detailed plan. In
addition to the above elements, States/locals should include
a rationale describing: (1) why it is not necessary to
evaluate specific facilities or source categories subject to
the minimum frequencies; and (2) why it is appropriate to
substitute other facilities.
If at the end of the first year, States/locals anticipate
or know that they will be unable to meet their two year
commitments by the end of the second year, they should
notify the Region and revise their CMS plan accordingly.
The "Source Compliance and State Action Reporting
Information Collection Request" (ICR), OMB Number 2060-0391,
will be revised to incorporate the development and
submission of this plan.
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APPENDIX A: CMS POLICY
IX COMPLIANCE MONITORING REPORTS
States/locals may continue to format compliance
monitoring reports as they deem appropriate; however, the
following basic elements should be addressed in the reports.
(1) General information--date, compliance monitoring
category (i.e., Full Compliance Evaluation, Partial
Compliance Evaluation, or Investigation), and official
submitting the report.
(2) Facility information--facility name, location,
mailing address, facility contact and phone number,
Title V designation and mega-site designation.
(3) Applicable requirements--all applicable
requirements including regulatory requirements and
permit conditions.
(4) Inventory and description of regulated emission
units and processes.
(5) Information on previous enforcement actions.
(6) Compliance monitoring activitiesprocesses and
emission units evaluated; on-site observations; whether
compliance assistance was provided and if so, nature of
assistance; any action taken by facility to come back
into compliance during on-site visit.
(7) Findings and recommendations relayed to the
facility during the compliance evaluation. Please
note, this does not apply to information traditionally
reserved for enforcement case files.
In providing the above information, States/locals should
reference or attach other relevant documents as appropriate
to avoid duplication. For example, the relevant section of
a Title V permit could be attached to the compliance
monitoring report rather than rewriting all of the
applicable requirements.
Compliance monitoring reports should be maintained and
made available to the Regions upon request. Regions shall
maintain similar files of regional activities and provide
Headquarters with access upon request.
X REPORTING
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APPENDIX A: CMS POLICY
Changes will be made in the national air compliance data
base (AIRS/AFS) to facilitate the reporting of information
consistent with the revised structure of this policy. In
addition, the ICR will be revised to incorporate the new
data elements. In order to collect compliance information
in a format that allows EPA to evaluate and compare
compliance monitoring programs, Regions and States/locals
will need to:
Continue to maintain records of compliance monitoring
activities, and report these activities and the results in
AIRS/AFS, or its successor, on a routine basis.
Continue to designate the High Priority Violator (HPV)
status of violating facilities in accordance with the EPA
HPV Policy dated December 22, 1998.
Utilize the following compliance monitoring categories to
report activities at the facility level in AIRS/AFS, or
its successor:
Full Compliance Evaluations
Partial Compliance Evaluations
Investigations
Report the following information for all Title V annual
compliance certification reviews in AIRS/AFS, or
its successor:
date due
date received
whether deviations were reported
date reviewed
compliance status
Please note: Regions shall enter the first three data
elements for each Title V compliance certification unless
otherwise negotiated with States/locals.
Enter the date and results of all stack tests in
AIRS/AFS, or its successor, and adjust the HPV status
as appropriate.
The compliance status of a facility will automatically
revert from *in compliance" to 'unknown" if a Full
Compliance Evaluation is not completed:
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APPENDIX A: CMS POLICY
within the recommended minimum evaluation
frequencies, or
in accordance with negotiated alternatives that
extend the recommended minimum evaluation frequencies.
XI EVALUATION/OVERSIGHT
At the end of each fiscal year, the Regions shall
evaluate whether the States/locals met their commitments,
and in those cases where they did not, determine why they
did not and what adjustments need to be made for the
following year. EPA Headquarters shall in turn conduct a
similar analysis nationally. This information should be
transmitted back to the appropriate officials in a timely
manner so that they can make mid-course corrections in their
program if necessary.
Regions periodically shall conduct more in-depth analysis
of the compliance monitoring program as a whole. They
should look beyond how successful States/locals have been in
meeting commitments, and evaluate for example whether
adequate inspector training is available; quality monitoring
evaluations are being conducted; violations are being found
and are significant enough to warrant enforcement action;
and data are accurately reported in a timely manner. They
should also assess whether States/locals are using an
appropriate mix of compliance monitoring techniques, and
making full use of all available data. In addition, Regions
should attempt to quantify the impact of the compliance
monitoring program on parameters such as compliance rates;
specific and general deterrence; and moving beyond
compliance. To the extent possible, Regions should inform
States/locals in advance of the criteria that will be used
in the more in-depth analyses.
Regions shall prepare and submit to Headquarters a plan
describing the approach and schedule they intend to use for
conducting these more in-depth evaluations.
Headquarters shall conduct similar evaluations of each
Region, and use the information to monitor implementation of
the policy; identify program deficiencies and successes;
establish national trends; compare programs; and develop new
national priorities. To the extent possible, Headquarters
should inform Regions in advance of the criteria that will
be used in evaluating Regional programs.
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APPENDIX B: AFS DATA DICTIONARY PAGES
APPENDIX B:
AFS Data Dictionary Pages
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APPENDIX B: AFS DATA DICTIONARY PAGES
CMS SOURCE CATEGORY INDICATOR
DATA ELEMENT NAME:
DESCRIPTION .... :
CMS SOURCE CATEGORY INDICATOR
A 1-POSITION FIELD USED TO INDICATE THE SOURCE
CATEGORY TO WHICH A FACILITY SUBJECT TO CMS BELONGS.
FORMAT ..
LENGTH ..
SECURITY
ALPHANUMERIC
1
UPDATE ACCESS RESTRICTED BY SPECIAL ACCESS CODE
OWNERSHIP
MANDATORY
COMPLIANCE
NO
REPORT
ACRONYM
CMSC
UPDATE
SCREEN
315
BROWSE
SCREEN
516
CARD
TYPE SEQ
COLS .
14
FILE
PLANT CMS
VALID VALUES ... :
A - TITLE V MAJOR
S - 80% SYNTHETIC MINOR
M - MEGA-SITE
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APPENDIX B: AFS DATA DICTIONARY PAGES
CMS SOURCE CATEGORY DESCRIPTION
DATA ELEMENT NAME:
CMS SOURCE CATEGORY DESCRIPTION
DESCRIPTION ...
A TWENTY CHARACTER DESCRIPTION OF A CMS SOURCE
CATEGORY INDICATOR.
FORMAT
LENGTH
ALPHANUMERIC
20
NONE
COMPLIANCE
NO
SECURITY
OWNERSHIP
MANDATORY
REPORT
ACRONYM
UPDATE
SCREEN
BROWSE
SCREEN
CARD
TYPE SEQ COLS.
FILE
CMSD
516
PLANT CMS
VALID VALUES ... :
CMS SOURCE CATEGORY DESCRIPTION IS GENERATED FOR VALID VALUES ON THE AFS
DESCRIPTION TABLE MAINTAINED WITHIN AFS IN THE AFS TABLE FILE.
A - TITLE V MAJOR
S - 80% SYNTHETIC MINOR
M - MEGA-SITE
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APPENDIX B: AFS DATA DICTIONARY PAGES
CMS MINIMUM FREQUENCY INDICATOR
DATA ELEMENT NAME: CMS MINIMUM FREQUENCY INDICATOR
DESCRIPTION . . . . : A 1-POSITION FIELD USED TO INDICATE THE NUMBER OF
YEARS ALLOWABLE BETWEEN FULL COMPLIANCE EVALUATIONS.
IT SHOULD BE USED FOR FACILITIES SUBJECT TO THE CMS.
FORMAT : ALPHANUMERIC
LENGTH : 1
SECURITY : UPDATE ACCESS RESTRICTED BY SPECIAL ACCESS CODE
READ ACCESS IS LIMITED TO USERS WITH SENSITIVE READ
AUTHORITY
OWNERSHIP : COMPLIANCE
MANDATORY : NO
REPORT
ACRONYM
UPDATE
SCREEN
CMSI 315
VALID VALUES . . .
BROWSE
SCREEN
516
CARD
TYPE SEQ
COLS .
15
FILE
PLANT CMS
1-9
Page 35
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
FISCAL YEAR OF FULL COMPLIANCE EVALUATION
DATA ELEMENT NAME: FISCAL YEAR OF FULL COMPLIANCE EVALUATION
DESCRIPTION .... : FISCAL YEAR USED TO IDENTIFY THE YEAR THAT A FULL
COMLIANCE EVALUATION HAS BEEN SCHEDULED AS DEFINED IN
THE CMS PLAN.
FORMAT : NUMERIC
LENGTH : 4; OCCURS 5 TIMES
SECURITY : UPDATE ACCESS RESTRICTED BY SPECIAL ACCESS CODE
READ ACCESS IS LIMITED TO USERS WITH SENSITIVE READ
AUTHORITY
OWNERSHIP : COMPLIANCE
MANDATORY : NO
REPORT UPDATE BROWSE CARD
ACRONYM
SCREEN
SCREEN
TYPE
SEQ
COLS .
FILE
CMYA
315
516
18
1
16-19
PLANT
CMS
CMYB
315
516
18
1
21-24
PLANT
CMS
CMYC
315
516
18
1
26-29
PLANT
CMS
CMYD
315
516
18
1
31-34
PLANT
CMS
CMYE
315
516
18
1
36-39
PLANT
CMS
VALID VALUES ... :
NUMERIC AND GREATER THAN OR EQUAL TO 2 0 02
Page 36
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
ON-SITE VISIT INDICATOR
DATA ELEMENT NAME:
DESCRIPTION .... :
ON-SITE VISIT INDICATOR
A Y/N INDICATOR USED TO IDENTIFY IF AN ON-SITE VISIT
IS PLANNED FOR A GIVEN FISCAL YEAR. DEFAULT VALUE IS
Y .
FORMAT ..
LENGTH ..
SECURITY
OWNERSHIP
MANDATORY
ALPHANUMERIC
1; OCCURS 5 TIMES
UPDATE ACCESS RESTRICTED BY SPECIAL ACCESS CODE
READ ACCESS IS LIMITED TO USERS WITH SENSITIVE READ
AUTHORITY
COMPLIANCE
NO
REPORT
UPDATE
BROWSE
CARD
ACRONYM
SCREEN
SCREEN
TYPE
SEQ
COLS .
FILE
CMOA
315
516
18
1
20
PLANT
CMS
CMOB
315
516
18
1
25
PLANT
CMS
CMOC
315
516
18
1
30
PLANT
CMS
CMOD
315
516
18
1
35
PLANT
CMS
CMOE
315
516
18
1
40
PLANT
CMS
VALID VALUES
Y - AN ON-SITE VISIT IS PLANNED
N - AN ON-SITE VISIT IS NOT PLANNED
Page 37
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
CMS COMMENT
DATA ELEMENT NAME: CMS COMMENT
DESCRIPTION . . . . : A 39-CHARACTER OPTIONAL FIELD WHICH PERMITS USERS TO
ENTER ADDITIONAL INFORMATION PERTAINING TO THE CMS
RECORD.
FORMAT : ALPHANUMERIC
LENGTH : 3 9
SECURITY : READ ACCESS IS LIMITED TO USERS WITH SENSITIVE READ
AUTHORITY
OWNERSHIP : COMPLIANCE
MANDATORY : NO
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
CM19 315 516 18 1 41-79 PLANT CMS
VALID VALUES ... :
UP TO 3 9 ALPHANUMERIC CHARACTERS
Page 38
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
DATE RECORD IS UPDATED
DATA ELEMENT NAME:
DESCRIPTION .... :
DATE RECORD IS UPDATED
GENERATED FIELD CONTAINING
WHICH CHANGES WERE MADE TO
RECORD.
THE MOST CURRENT DATE ON
INFORMATION CONCERNING A
FORMAT ...
LENGTH . . .
SECURITY .
OWNERSHIP
MANDATORY
ALPHANUMERIC
6.0
NONE
BOTH
NO
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
DUAB
512
ASBESTOS PERFORMANCE
DUO 0
135
INVENTORY SIP
DUO 7
135
INVENTORY COMMENT
DU1H
504
HISTORY PLANT
DU11
500
PLANT GENERAL
DU12
501
POLLUTANT PLANT
DU13
502
AIR PGM PLANT
DU14
503
AIR PGM POLLUTANT
DU15
505
PLANT FEE
DU16
506
PLANT MAIL
DU17
507
ACTION PLANT
DU18
508
COMMENT PLANT
DU19
516
PLANT CMS
DU21
520
STACK GENERAL
DU22
521
POLLUTANT STACK
DU2 3
522
COMMENT STACK
DU3H
523
HISTORY POINT
DU31
530
POINT GENERAL
DU32
531
POLLUTANT POINT
DU33
532
AIR PGM POINT
DU34
534
CONT EMIS MONITOR
DU35
535
CONT EMIS EER
DU3 6
536
POINT TANK
DU37
537
ACTION POINT
DU3 8
538
COMMENT POINT
DU41
540
SEGMENT GENERAL
DU42
541
POLLUTANT SEGMENT
DU43
542
POLLUTANT CHEMICAL
DU44
543
COMMENT SEGMENT
Page 39
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
DATE RECORD IS UPDATED (CONTINUED)
PROJECTED POLLUTANT
PERMIT
ASSOCIATIONS
EVENT TRACKING ACTION
VALID VALUES . . . :
DATE FORMAT YYMMDD
Page 40
DU48 544
ASDU 551
553
PDRU 554
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
PERSON UPDATING RECORD
DATA ELEMENT NAME: PERSON UPDATING RECORD
DESCRIPTION .... : GENERATED FIELD CONTAINING THE USER ID OF THE PERSON
WHO LAST UPDATED THE RECORD.
FORMAT : ALPHANUMERIC
LENGTH : 3
SECURITY : NO
OWNERSHIP : BOTH
MANDATORY : NO
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
PU19 516 PLANT CMS
VALID VALUES ... :
ANY NCC USER ID
Page 41
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA PLANT/POINT COMPLIANCE STATUS
DATA ELEMENT NAME:
EPA PLANT/POINT COMPLIANCE STATUS
DESCRIPTION ....
A ONE-CHARACTER CODE WHICH REFLECTS THE EPA'S
DETERMINATION OF THE COMPLIANCE OF A FACILITY (OR
POINT WITHIN A FACILITY) WITH REGARD 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 AIR
PROGRAM VALUES ARE IN TURN DISPLAYED AT THE PLANT
GENERAL LEVEL. POINT LEVEL DATA IS NOT EVALUATED FOR
THE PURPOSE OF DETERMINING WORST CASE SCENARIOS.
FORMAT ...
LENGTH ...
SECURITY .
OWNERSHIP
MANDATORY
ALPHANUMERIC
1 . 0
UPDATE ACCESS LIMITED TO EPA COMPLIANCE
COMPLIANCE
NO
REPORT
ACRONYM
ECS 1
DCS 1
ECA1
DCA1
ECA3
DC A3
ECH1
ESH1
DCH1
DSH1
ECH3
ESH3
UPDATE
SCREEN
BROWSE
SCREEN
502
CASE>
532 32
CASE>
504
533
SEQ
COLS .
20
FILE
PLANT GENERAL
PLANT GENERAL
AIR PGM PLANT
AIR PGM PLANT
AIR PGM POINT
AIR PGM POINT
HISTORY PLANT
HISTORY PLANT
HISTORY PLANT
HISTORY PLANT
HISTORY POINT
HISTORY POINT
Page 42
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA PLANT/POINT COMPLIANCE STATUS (CONTINUED)
DCH3
DSH3
VALID VALUES ... :
(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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
HISTORY POINT
HISTORY POINT
Page 43
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA PLANT/POINT COMPLIANCE STATUS DESCRIPTION
DATA ELEMENT NAME:
EPA PLANT/POINT COMPLIANCE STATUS DESCRIPTION
DESCRIPTION ...
A TWENTY-FIVE CHARACTER DESCRIPTION OF AN EPA
COMPLIANCE STATUS CODE.
FORMAT
LENGTH
ALPHANUMERIC
25.0
NONE
COMPLIANCE
NO
SECURITY
OWNERSHIP
MANDATORY
REPORT
ACRONYM
UPDATE
SCREEN
BROWSE
SCREEN
CARD
TYPE SEQ COLS.
FILE
EDS 1
DDS1
EDA1
DDA1
EDA3
DDA3
EDH1
DDH1
EDH3
DDH3
500
502
532
PLANT GENERAL
PLANT GENERAL
AIR PGM PLANT
AIR PGM PLANT
AIR PGM POINT
AIR PGM POINT
HISTORY PLANT
HISTORY PLANT
HISTORY POINT
HISTORY POINT
VALID VALUES ... :
THE EPA COMPLIANCE STATUS DESCRIPTION IS GENERATED FOR VALID VALUES ON THE AFS
DESCRIPTION TABLE MAINTAINED WITHIN AFS IN THE AFS TABLE FILE.
(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
Page 44
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA PLANT/POINT COMPLIANCE STATUS DESCRIPTION (CONTINUED)
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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 45
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE PLANT/POINT COMPLIANCE STATUS
DATA ELEMENT NAME: STATE PLANT/POINT COMPLIANCE STATUS
DESCRIPTION : A ONE-CHARACTER CODE WHICH REFLECTS THE STATE AGENCY'S
DETERMINATION OF THE COMPLIANCE STATUS OF A FACILITY
(OR POINT WITHIN A FACILITY) WITH REGARD 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. POINT
LEVEL DATA IS NOT EVALUATED FOR THE PURPOSE OF
DETERMINING WORST-CASE SCENARIOS.
FORMAT ...
LENGTH ...
SECURITY .
OWNERSHIP
MANDATORY
ALPHANUMERIC
1 . 0
NONE
COMPLIANCE
YES
REPORT
ACRONYM
UPDATE
SCREEN
BROWSE
SCREEN
CARD
TYPE
SCSI 500
SCA1 5 02
SCH1 504
SSH1
SCA3 332 532 32
SCH3 533
SSH3
SEQ
COLS .
19
FILE
PLANT GENERAL
AIR PGM PLANT
HISTORY PLANT
HISTORY PLANT
AIR PGM POINT
HISTORY POINT
HISTORY POINT
Page 46
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE PLANT/POINT COMPLIANCE STATUS (CONTINUED)
VALID VALUES ... :
(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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 47
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE PLANT/POINT COMPLIANCE STATUS DESCRIPTION
DATA ELEMENT NAME: STATE PLANT/POINT COMPLIANCE STATUS DESCRIPTION
DESCRIPTION .... : A TWENTY-FIVE CHARACTER COMPLIANCE STATUS CODE
DESCRIPTION.
FORMAT : ALPHANUMERIC
LENGTH : 25.0
SECURITY : NONE
OWNERSHIP : COMPLIANCE
MANDATORY : NO
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
SDS1 5 00 PLANT GENERAL
SDA1 5 02 AIR PGM PLANT
SDH1 HISTORY PLANT
SDA3 532 AIR PGM POINT
SDH3 HISTORY POINT
VALID VALUES ... :
STATE COMPLIANCE STATUS DESCRIPTION IS GENERATED FOR VALID VALUES ON THE AFS
DESCRIPTION TABLE MAINTAINED WITHIN AFS IN THE AFS TABLE FILE.
(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
Page 48
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE PLANT/POINT COMPLIANCE STATUS DESCRIPTION (CONTINUED)
7 - IN VIOLATION - UNKNOWN WITH REGARD TO SCHEDULE
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 49
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA POLLUTANT COMPLIANCE STATUS
DATA ELEMENT NAME: EPA POLLUTANT COMPLIANCE STATUS
DESCRIPTION : A ONE-CHARACTER CODE WHICH REFLECTS THE EPA'S
DETERMINATION OF THE COMPLIANCE OF A FACILITY (OR
POINT WITHIN A FACILITY) WITH REGARD 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 AIR
PROGRAM VALUES ARE IN TURN DISPLAYED AT THE PLANT
GENERAL LEVEL. POINT LEVEL DATA IS NOT EVALUATED FOR
THE PURPOSE OF DETERMINING WORST CASE SCENARIOS.
FORMAT ..
LENGTH ..
SECURITY
OWNERSHIP
MANDATORY
ALPHANUMERIC
1 . 0
NONE
COMPLIANCE
NO
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
ECAP 303 503 13 1 28 AIR PGM PLLT
DCAP AIR PGM PLLT
VALID VALUES ... :
(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
Page 50
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA POLLUTANT COMPLIANCE STATUS (CONTINUED)
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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 51
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA POLLUTANT COMPLIANCE STATUS DESCRIPTION
DATA ELEMENT NAME:
EPA POLLUTANT COMPLIANCE STATUS DESCRIPTION
DESCRIPTION ...
A TWENTY-FIVE CHARACTER DESCRIPTION OF AN EPA
POLLUTANT COMPLIANCE CODE.
FORMAT
LENGTH
ALPHANUMERIC
25.0
NONE
COMPLIANCE
NO
SECURITY
OWNERSHIP
MANDATORY
REPORT
ACRONYM
UPDATE
SCREEN
BROWSE
SCREEN
CARD
TYPE SEQ COLS.
FILE
EDAP
DDAP
503
AIR PGM PLLT
AIR PGM PLLT
VALID VALUES ... :
EPA POLLUTANT COMPLIANCE STATUS DESCRIPTION IS GENERATED FOR VALID VALUES ON
THE AFS DESCRIPTION TABLE MAINTAINED WITHIN AFS IN THE AFS TABLE FILE.
(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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
Page 52
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
EPA POLLUTANT COMPLIANCE STATUS DESCRIPTION (CONTINUED)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 53
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE POLLUTANT COMPLIANCE STATUS
DATA ELEMENT NAME: STATE POLLUTANT COMPLIANCE STATUS
DESCRIPTION : A ONE-CHARACTER CODE WHICH REFLECTS THE STATE AGENCY'S
DETERMINATION OF THE COMPLIANCE STATUS OF A FACILITY
(OR POINT WITHIN A FACILITY) WITH REGARD 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. POINT
LEVEL DATA IS NOT EVALUATED FOR THE PURPOSE OF
DETERMINING WORST-CASE SCENARIOS.
FORMAT ..
LENGTH ..
SECURITY
OWNERSHIP
MANDATORY
ALPHANUMERIC
1 . 0
NONE
COMPLIANCE
YES
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
SCAP 303 503 13 1 24 AIR PGM PLLT
VALID VALUES ... :
(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
Page 54
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE POLLUTANT COMPLIANCE STATUS (CONTINUED)
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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 55
-------
APPENDIX B: AFS DATA DICTIONARY PAGES
STATE POLLUTANT COMPLIANCE STATUS DESCRIPTION
DATA ELEMENT NAME: STATE POLLUTANT COMPLIANCE STATUS DESCRIPTION
DESCRIPTION .... : A TWENTY-FIVE CHARACTER POLLUTANT COMPLIANCE STATUS
CODE DESCRIPTION.
FORMAT : ALPHANUMERIC
LENGTH : 25.0
SECURITY : NONE
OWNERSHIP : COMPLIANCE
MANDATORY : YES
REPORT UPDATE BROWSE CARD
ACRONYM SCREEN SCREEN TYPE SEQ COLS. FILE
SDAP 5 03 AIR PGM PLLT
VALID VALUES ... :
STATE POLLUTANT COMPLIANCE STATUS CODE DESCRIPTION IS GENERATED FOR VALID
VALUES ON THE AFS DESCRIPTION TABLE MAINTAINED WITHIN AFS IN THE AFS TABLE
FILE .
(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
U - UNKNOWN BY EVALUATION CALCULATION (GENERATED VALUE-NOT AVAILABLE FOR
INPUT)
Page 56
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APPENDIX B: AFS DATA DICTIONARY PAGES
STATE POLLUTANT COMPLIANCE STATUS DESCRIPTION (CONTINUED)
ON SCHEDULE
5 - MEETING COMPLIANCE SCHEDULE
IN COMPLIANCE
C - IN COMPLIANCE WITH PROCEDURAL REQUIREMENTS
4 - IN COMPLIANCE BY OFF-SITE EVALUATION
3 - IN COMPLIANCE BY ON-SITE EVALUATION
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)
Page 57
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APPENDIX C: BATCH TRANSACTION LAYOUT
APPENDIX C
BATCH TRANSACTION LAYOUT
Page 58
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APPENDIX C: BATCH TRANSACTION LAYOUT
AFS PLANT CMS
TRANSACTION TYPE 18
Column
Field
Name of Field
From
Thru
Lenath
Remarks
1
State Code
1
2
2
Key
2
County Code
3
5
3
Key
3
Plant ID
6
10
5
Key
4
Transaction Type
11
12
2
Key, Always 18
5
Sequence Number
13
13
1
Key, Always 1
6
Source Category
14
14
1
7
Minimum Frequency
Indicator
15
15
1
8
Fiscal Year of FCE-Year A
16
19
4
9
Onsite Visit-Indicator A
20
20
1
10
Fiscal Year of FCE-Year B
21
24
4
11
Onsite Visit-Indicator B
25
25
1
12
Fiscal Year of FCE-Year C
26
29
4
13
Onsite Visit-Indicator C
30
30
1
14
Fiscal Year of FCE-Year D
31
34
4
15
Onsite Visit-Indicator D
35
35
1
16
Fiscal Year of FCE-Year E
36
39
4
17
Onsite Visit-Indicator E
40
40
1
18
Comment
41
79
39
19
Update Code
80
80
1
Key, Always A or
Page 59
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APPENDIX D: AFS SCREENS
APPENDIX D
ADDITIONAL
AFS SCREENS
Page 60
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APPENDIX D: AFS SCREENS
UPDATE PLANT INFORMATION MENU - SCREEN 040
DATE :
05/17/01 AIRS FACILITY SUBSYSTEM - UPDATE PGM: AFP040
SCREEN:
040
PLANT INFORMATION MAP: AFM0401
1
GENERAL INFORMATION (300)
2
POLLUTANT INFORMATION (301)
3
AIR PROGRAMS (302)
4
POLLUTANT AIR PROGRAMS (303)
5
PERMIT ADMINISTRATION (060)
6
MAILING LABEL INFORMATION (305)
7
ACTIONS (30 6)
8
COMMENTS (307)
9
ASBESTOS INFORMATION (042)
10
HIGH PRIORITY VIOLATOR UPDATE UTILITY (314)
11
COMPLIANCE MONITORING STRATEGY (315)
ENTER MENU SELECTION:
PF1=HELP
PF3=END PF4=MAIN
PF5=TERM PF10=SCRN PF12=BRWS SCREEN:
BROWSE PLANT INFORMATION MENU - SCREEN 050
DATE :
05/17/01 AIRS FACILITY SUBSYSTEM - BROWSE PGM: AFP050
SCREEN:
050
PLANT INFORMATION MAP: AFM0501
1
GENERAL INFORMATION (500)
2
POLLUTANT INFORMATION (501)
3
AIR PROGRAMS (502)
4
POLLUTANT AIR PROGRAMS (503)
5
HISTORICAL COMPLIANCE INFORMATION (504)
6
PERMIT ADMINISTRATION (080)
7
8
MAILING LABEL INFORMATION (50 6)
ACTIONS (507)
9
COMMENTS (508)
10
ASBESTOS INFORMATION (052)
11
PLANT SUMMARY (509)
12
HIGH PRIORITY VIOLATOR TRACKING (514)
13
HPV FLAG ACTION PATHWAY MATRIX (515)
14
COMPLIANCE MONITORING STRATEGY (516)
ENTER MENU SELECTION:
PF1=HELP
PF3=END PF4=MAIN
PF5=TERM PF10=SCRN SCREEN:
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APPENDIX D: AFS SCREENS
UPDATE PLANT COMPLIANCE MONITORING STRATEGY - SCREEN 315
DATE : 09/20/01 AIRS FACILITY SUBSYSTEM - UPDATE PGM: AFP315
SCREEN: 315 COMPLIANCE MONITORING STRATEGY MAP: AFM3151
10000 TEST PLANT 123 TEST DRIVE
( 2001/09/17 - JH1 )
CMS SOURCE CATEGORY: A
CMS MINIMUM FREQUENCY INDICATOR: 6
PLANNED YEAR (S) OF FULL COMPLIANCE EVALUATION (FCE) :
FISCAL
YEAR
A
ON-SITE
VISIT
PLANNED
(Y/N)
FISCAL
YEAR
B
2011
ON-SITE
VISIT
PLANNED
(Y/N)
Y
FISCAL
YEAR
C
2012
ON-SITE
VISIT
PLANNED
(Y/N)
N
FISCAL
YEAR
D
2015
ON-SITE
VISIT
PLANNED
(Y/N)
Y
FISCAL
YEAR
E
2020
ON-SITE
VISIT
PLANNED
(Y/N)
N
COMMENT: ROBS TEST COMMENT
PF1=HELP PF3=END PF4=MAIN PF5=TERM PF10=SCRN SCREEN:
Page 62
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APPENDIX E: MINIMUM DATA REQUIREMENTS
APPENDIX E
Minimum Data Requirements
for
Clean Air Act Stationary Source Compliance
Page 63
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Matrix of National Minimum Data Requirements (MDRs)
for
Clean Air Act Stationary Source Compliance
New reporting in AFS data fields or data reporting are identified by italics
National Minimum Data Requirements (MDRs)
Clean Air Act Stationary Source Compliance Program
Implementation in AFS
Modifications to
Data Management
Reporting Guidance
AFS Responsible
Agency
Data Covered by Current 1998 ICR
Identification Data -
I. Facility Name, 2. Facility State, 3. Facility County, 4. Facili
ID Number, 5. Facility Street Address, 6. Facility City, 7.
Facility Zip Code,
8. SIC Code, 9. Government Ownership Indicator, 10. Current
Significant Violator Status 1
Resulated Air Prosramfs") -
II. Plant Air Program(s), 12. Plant Air Program Operating
Status
Resulated Pollutantss") Within an Air Prosram -
13. Pollutant Type, 14. Classification,
15. Attainment Status, 16. Compliance Status
Minimum Reoortable Actions Within Air Prosrams -
1. Update MDRs
y
None
State/locals, EPA
Regions
17. Action Number, 18. Action Type, 19. Date Achieved
20. Minimum Reoortable Action Tvoes -
Inspections, Stack Tests 2, Notices of Violation, Administrate
Orders (with penalty amounts), Civil Referrals * (with penalty
amounts), Criminal Referrals*, Day Zero
Minimum Reoortable Actions Within Air Prosrams -
21. All actions in HPV pathway from 'Initiating' through
'Addressing' and associated dates
HPV Data Not Covered by 1998 ICR
HPV Actions
22. HPV 'Resolving' and/or close-out actions and associated
dates
23. Link all actions in sequence by use of AFS 'Day Zero'
action linking 3
1. Update facility High
Priority Violation (HPV) 1
designations by updating all
applicable underlying action
data
1. Simplified and
accurate tracking of
HPV information 4
EPA Regions 3
States/locals- Data
Source 3
Plant HPV Record -
24. HPV' Status field and associated effective date field
(eliminates Item 10 above)
1. Add Plant HPV record
type to AFS
2. Generate the HPV status
and update Effective Date
field
1. Elimination of
Significant Violator
SVI1 'flag' update
reporting 4
System generated
Page 64
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Continued
Matrix of National Minimum Data Requirements (MDRs)
for
Clean Air Act Stationary Source Compliance
New reporting in AFS data fields or data reporting are identified by italics
National Minimum Data Requirements (MDRs)
Clean Air Act Stationary Source Compliance Program
Implementation in AFS
Modifications to
Data Management
Reporting Guidance
AFS Responsible
Agency
CMS Data Not Covered by 1998 ICR
Plant Comvliance Monitoring Strateev (CMS) Record -
25. CMS Source Category field
26. Minimum Frequency (MF) Indicator field*
1. New AFS record type-
Plant Compliance
Monitoring Strategy
2. Add 1-character CMS
Source Category Field
(CMSC)
3. Add valid values for
CMSC to indicate Title V,
Mega-Site or SM source =>
80% of Title VPTE threshold
4. Add 1 character-numeric
MF Indicator field (CMSI)
5. Support valid values 1 -9
1. Greater speciation
of Title V and
Synthetic Minor
sources by indicating
Mega-Sites and SM
source => 80% of
Major PTE threshold
2. Identification of
Full Compliance
Evaluation (FCE)
determination
frequency period for
facility
Items 25 and 26:
Only EPA may
update these fields;
State/locals provide
data input via CMS
plans
Annual CMS Plan
27. FCE Fiscal Year fields: (CMYA-CMYE) *
28. FCE On-Site Visit Indicator fields:
(CMOA-CMOE) *
1. Addfive, 4-character
numeric fields
(CMYA, CMYB, CMYC,
CMYD,CMYE) for tracking
ofplanned FCE fiscal year.
2. Update annual date values
beginning 2002
3. Addfive, 1-character
alphanumeric fields (CMOA,
CMOB, CMOC, CMOD,
CMOE) associated with FCE
Fiscal Year field
4. Update CMOA-CMOE
with T' (yes-on site) or
'N'(no-ojf site); the default
value for the field will be T'
1. Assessment of FY
compliance
evaluation and on-
site visit field data
used to support
revised CMS
Items 27 and 28:CMS
plan submitted by
States/Locals to EPA
with optional
reporting to AFS
Annual CMS Plan
29. Identify facilities without a timely FCE
1. Develop AFS utility that
reads MF Indicator field,
current date and EPA/State
Date of Last FCE. Plants
with FCE and date achieved
that falls outside the MF
period will have their
Federal Compliance Status
Code changed to 'Unknown
By Evaluation Calculation'
2. Develop utility that
removes previously generated
'Unknown By Evaluation
Calculation' value when new
FCE updated to plant
1. Identification of
facilities without
timely FCE
2. Automated update
of facility status upon
completion of FCE
AFS Generated
Page 65
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Continued
Matrix of National Minimum Data Requirements (MDRs)
for
Clean Air Act Stationary Source Compliance
New reporting in AFS data fields or data reporting are identified by italics
National Minimum Data Requirements (MDRs)
Clean Air Act Stationary Source Compliance Program
Implementation in AFS
Modifications to
Data Management
Reporting Guidance
AFS Responsible
Agency
CMS Data Not Covered by 1998 ICR
Actions Within Air Programs -
30. Report all Full Compliance Evaluations (FCE)
1. Add State and National
action types to action tables,
including FCE with on-site
visit and FCE without on-site
visit
2. Update all FCE actions in
Plant level action record
Examples of FCE action
types are provided in Table I
to this matrix
1. Reporting of
evaluation activities
replaces Level 2
inspection reporting
State/locals, EPA
Regions
Actions Within Air Programs -
31. Report all Partial Compliance Evaluations (PCE)
1. Add Regional and
National action types to
action tables, including PCE
2. Update all PCE actions in
Plant level action record;
including PCEs, Stack Tests
and Title VAnnual
Compliance Certification
Reviews
Examples of PCE action
types are provided in Table I
to this matrix
1. Optional reporting
of all evaluation
activities
State/locals, EPA
Regions
Actions Within Air Programs -
32. Report all Investigations
1. Add Regional and
National action types to
action tables for
Investigations
2. Investigations
(Investigation Initiated*,
Investigation Completed)
1. New reporting of
all Investigation
activities
State/locals, EPA
Regions
Actions Within Air Proerams-
33. Report performance of all stack tests
1. Update Results Code for
all stack tests reported
2. Update action pollutant
code for all stack tests
3. Update pollutant
compliance status as
appropriate
Examples of Stack Test
action types are provided in
Table I to this matrix
1. Reporting of
Results (Pass/Fail)
for all stack tests
2. Optional reporting
of Action Pollutant
data related to stack
tests conducted
State/locals, EPA
Regions
Actions Within Air Programs -Title VAnnual Comvliance
Certifications
34. State Review Date
1. Report agency reviews of
Annual Compliance
Certifications, including
Date Achieved
1. Reporting of
annual compliance
certifications reviews
State/locals
Page 66
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Continued
Matrix of National Minimum Data Requirements (MDRs)
for
Clean Air Act Stationary Source Compliance
New reporting in AFS data fields or data reporting are identified by italics
National Minimum Data Requirements (MDRs)
Clean Air Act Stationary Source Compliance Program
Implementation in AFS
Modifications to
Data Management
Reporting Guidance
AFS Responsible
Agency
CMS Data Not Covered by Current 1998 ICR
Actions Within Air Programs - Title VAnnual Comvliance
Certifications
35. State Results of Certification Review
1. Update these actions with
Results Code. Valid values
are: 'In Violation', In
Compliance' and 'Unknown'
1. Reporting of
annual compliance
certifications review
results
State/locals
Actions Within Air Programs - Title VAnnual Comvliance
Certifications
36. Due Date
1. Update actions with Action
Type 'Title VAnnual
Compliance Certification
Received' with associated
Date Scheduled (for 'Due
Date )
1. Reporting of
annual compliance
certification due
dates to AFS
EPA Regions
Optional for States
Option for System
Generation 5
Actions Within Air Programs - Title VAnnual Comvliance
Certifications
3 7. EPA Received Date
1. Update actions with Action
Type 'Title VAnnual
Compliance Certification
Received' with associated
Date Achieved
(for Received Date')
1. Reporting of
annual compliance
certifications
EPA Regions
Actions Within Air Programs - Title VAnnual Comvliance
Certifications
38. EPA Reviewed Date
1. Update actions with Action
Type 'Title VAnnual
Compliance Certification
Reviewed' with Date
Achieved
1. Reporting to AFS
of EPA review of Title
VAnnual Compliance
Certifications
EPA Regions
Actions Within Air Programs - Title VAnnual Comvliance
Certifications
39. EPA Results of Certification Review
1. Update the 'Title VAnnual
Compliance Certification
Reviewed' actions with
Results Code. Valid values
are: 'In Violation', 'In
Compliance' and 'Unknown'
1. Reporting of
annual compliance
certifications review
results
EPA Regions
Actions Within Air Programs - Title VAnnual Comvliance
Certifications
40. Deviations Identified by Facility
1. Update RD81 field on
'Title VAnnual Compliance
Certification Reviewed'
actions with 'Deviation
Value' of 'Y'(yes) or 'N'(no)
1. Use ofRD81 as
data field for
recording 'Deviation
value'
EPA Regions
Page 67
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Endnotes:
* Indicates Enforcement Sensitive
1. The use of the 'Significant Violator' (SV) flag and three historic SV flag value fields on the AFS Plant General Record were eliminated in October,
1999. The S V flag was replaced by the use of the HPV field, located on the Plant HPV record. Automated updating of the HPV flag from underlying
linked AFS action data commenced in January 2001.
2. See Item 33.
3. The lead agency is responsible for reporting their own actions; action linking within AFS is optional for States and mandatory for EPA via
information provided by States pursuant to High Priority Violation (HPV) policy.
4. See "Simplified and Accurate Tracking of High Priority Violation (HPV) Information in AFS," June 2, 2000
5. Globally calculated from Permit Issuance Date by HQ, or from other criteria as specified by Regions.
Page 68
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Table I
Example State Only Action Types for CMS
Nat'l (ANT1)
National Description
Full Compliance Evaluations (FCE)
FS (new)
State Conducted Full Compliance Evaluation (FCE) / On-site
FF (new)
State Conducted Full Compliance Evaluation (FCE) / Off-site
Investigations
SI (new)
State Investigation Initiated3
SC (new)
State Investigation Conducted
Title V Annual Compliance Certifications
SR (existing)
Annual Compliance Certification State Review
CB (new)
Title V Annual Compliance Certification Due/Received by State
Stack Tests
3 A (existing)
State Req'd (Owner/Oper. Conducted) Stack Test Observed & Reviewed
TR (new)
State Req'd (Owner/Oper. Conducted) Stack Test Not Observed, but Reviewed
6C (existing)
State Conducted Stack Test
Partial Compliance Evaluations (PCE) ON-SITE 4
PS (new)
State Partial Compliance Evaluation (PCE) / On-site
Partial Compliance Evaluations (PCE) OFF-SITE
PX (new)
State Partial Compliance Evaluation (PCE) / Off-Site
State Investigation Initiated is added for optional use and is enforcement sensitive.
4 Examples of State PCE's with an on-site visit could include: State Visible Emission (VE) Observation
(Method 9); State Complaint Inspection; State Case Development Inspection; State Leak Detection Test (LDAR); State
Sample(s) Taken; State Conducted Continuous Monitoring System QA Audit; Source Conducted Continuous
Monitoring System QA, Observed & Reviewed by State (60.13, App F)
5 Examples of State PCE's without an on-site visit could include: Source Conducted Continuous Monitoring
System QA, Not Observed, Reviewed by State (60.13, APP F); Source Conducted Continuous Monitoring System QA,
Not Observed, Not Reviewed by State (60.13, App F); State Review of Qtrly EER; State Review of Semi-annual
Deviation Report (SDR); State Review of Sample Test Results; State Review of Facility Response to Information
Request
Page 69
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Table I
Example EPA Only Action Types for CMS
Nat'l (ANT1)
National Description
Full Compliance Evaluations (FCE)
FE (new)
EPA Conducted Full Compliance Evaluation (FCE) / On-site
FZ (new)
EPA Conducted Full Compliance Evaluation (FCE) / Off-site
Investigations
EI (new)
EPA Investigation Initiated 6
EC (new)
EPA Investigation Conducted
Title V Annual Compliance Certifications
ER (existing)
Annual Compliance Certification EPA Review
CC (new)
Title V Annual Compliance Certification Due/Received by EPA
Stack Tests
TO(new)
EPA Req'd (Owner/Oper. Conducted) Stack Test Observed & Reviewed
TE (new)
EPA Req'd (Owner/Oper. Conducted) Stack Test Not Observed, but Reviewed
2A (existing)
EPA Conducted Stack Test
Partial Compliance Evaluations (PCE) ON-SITE 7
ES (new)
EPA Partial Compliance Evaluation (PCE) / On-site
Partial Compliance Evaluations (PCE) OFF-SITE 8
EX (new)
EPA Partial Compliance Evaluation (PCE) / Off-Site
6 EPA Investigation Initiated is added for optional use and is enforcement sensitive.
j
Examples of EPA PCE's with an on-site visit could include: EPA Visible Emission (VE) Observation
(Method 9); EPA Complaint Inspection; EPA Case Development Inspection; EPA Leak Detection Test (LDAR); EPA
Sample(s) Taken; EPA Conducted Continuous Monitoring System QA Audit; Source Conducted Continuous Monitoring
System QA, Observed & Reviewed by EPA (60.13, App F)
Examples of EPA PCE's without an on-site visit could include: Source Conducted Continuous Monitoring
System QA, Not Observed, Is Reviewed by EPA (60.13, APP F); Source Conducted Continuous Monitoring System
QA, Not Observed, Not Reviewed by EPA (60.13, App F); EPA Review of Qtrly EER; EPA Review of Semi-annual
Deviation Report (SDR); EPA Review of Sample Test Results; EPA Review of Facility Response to Information
Request
Page 70
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TABLE II
SUMMARY OF NATIONAL MINIMUM DATA REQUIREMENTS (MDR'S)
FOR CLEAN AIR ACT STATIONARY SOURCE COMPLIANCE
MARCH 2002
Unless otherwise noted, both Regions and States/Locals report their data
Identification Covered bv 1998 ICR
1. Facility Name Yes
2. State Yes
3. County Yes
4. Facility Number Yes
5. Street Yes
6. City Yes
7. Zip Code Yes
8. SIC Code Yes
9. Government Ownership Yes
10. HPV Status (replaces SV status) Yes 1
Compliance Monitoring Strategy
11. CMS Source Category 2 No
12. CMS Minimum Frequency Indicator 2 No
Regulated Air ProgramCsl
13. Air Program Yes
14. Operating Status Yes
Regulated PollutantCsl within Air ProgramCsl
15. Pollutant(s) Yes
16. Classification(s) Yes
17. Attainment Status Yes
18. Compliance Status Yes
Actions Within Air Programs 3
19. Minimum Reportable Actions are:
Notice of Violation(s) Yes
Administrative Order(s) and penalty amounts Yes
(Includes Enforcement Orders, Consent Decrees and Consent Agreements)
Civil Referrals and penalties Yes
Day Zero Yes
Addressing actions 4 Yes
Resolving actions 5 Yes
Full Compliance Evaluations (replaces Inspection actions) Yes 6
Stack Tests Yes 7
Title V Annual Compliance Certification Received 8'13 No
Title V Annual Compliance Certification Reviewed 9'10 No
Investigations 11 No
Additional action information:
20. Key Action 12 No
21. Results Code 7'10 No
22. RD81 (Certification Deviations)8'9 No
23. Date Scheduled 13 No
Page 71
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Endnotes:
1. Significant violator status (SV) is an obsolete field. It was replaced by the High Priority Violation (HPV) status in
June 2000 with the implementation of the HPV tracking program. Modifications to AFS to support this program were
put into production during January 2001. HPV status is system generated.
2. EPA entry into AFS; States/Locals provide information (or negotiate with EPA region for data entry rights).
3. Includes action number, action type, and date achieved. Penalty amount is also included where appropriate.
4. Examples of addressing actions include, but are not limited to: State/EPA Civil Action; Source returned to
compliance by State/EPA with no further action required; State/EPA Administrative Order; State/EPA Consent Decree .
5. Examples of resolving actions include Violation Resolved by State/EPA; State/EPA Closeout Memo Issued; Section
113(d) Penalty Collected; Section 113(d) Complaint Withdrawn. HPV lead agency responsible for data entry of actions
into AFS.
6. Inspection reporting is now replaced by Full Compliance Evaluations per the revised CMS policy.
7. Data fields reported for stack tests will now include Results code (pass/fail). Please note that an optional action
pollutant field is available to report stack tests by pollutant.
8. EPA reports and enters into AFS unless otherwise negotiated.
9. Annual Compliance Certification deviation(s) will be indicated in RD81 for EPA reviews.
10. Result codes for Annual Compliance Certification reviews are: in compliance, in violation and unknown.
11. State/EPA Investigation Initiated and State/EPA Investigation Conducted. State/EPA Investigation Initiated is
added for optional use and is enforcement sensitive.
12. The key action field (a Y/N field) used on a Day Zero action type will initiate a violation pathway. Violation
pathways are one form of action linking and are required for the HPV tracking program. Data entry can be negotiated
with State/Local agencies as they report their HPV information.
13. The Due date of a Title V Annual Compliance Certification will be reported as a date scheduled on the "Title V
Annual Compliance Certification Due/Received by EPA" action.
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