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Webinar: National Enforcement Initiative Reporting for FY 2014
To Access the Webinar: And Dial: Conference Call #: ID#: # (If you are unable to dial in to the conference line, you can listen to the Webinar on your computer speakers.)
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Webinar: National Enforcement Initiative Reporting for FY 2014
Daniel Palmer and David Sprague, OC March 2014
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*** Questions to Follow Each Presentation ***
Agenda NEI Reporting for FY 2014 General NEI Reporting – Reminders and what has changed from FY2013 Municipal NEI CAFO NEI NSR/PSD NEI Air Toxics NEI Mineral Processing NEI Energy Extraction NEI NEI Reporting Cheat Sheets NEI ICIS Reports *** Questions to Follow Each Presentation ***
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FY 14 NEI Reporting - General
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NEI Reporting for FY14: Continuing the Transition to Reporting Through ICIS
NEI Reporting Guide will be posted at MY with the overall FY 14 Reporting Plan It will be available on the intranet at: NEI reporting effort is focused on assuring we have reliable data for: SITs and OECA and Regional enforcement managers to manage and track the NEIs, and Conveying progress on the NEIs via the OECA NEI Website:
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Continuing the Move to ICIS for NEI Data Collection
Historically, much of the NEI data had been captured using manual spreadsheets maintained by individuals In FY11 OECA began a process of moving the NEI data and data collection process to ICIS This process continued in FYs 12 and 13 and is continuing in FY 14 We expect to complete this process in FY 14 We also expect to greatly enhance the NEI data available via the OSMS/ICIS Dashboard - but timing for this is $ dependent
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New ICIS NEI Data Fields
Several new fields were created in ICIS in FY 2011 to facilitate tracking of NEI data: Universe Indicator field (on the facility screen) Controlled/Addressed data field (on the compliance determination screen) No Further Action data field (on the compliance determination screen) Initiated Action field (on the compliance determination screen)
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New ICIS Data Field: Universe Indicator
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New ICIS Data Field: Universe Indicator
Key Points re: the Universe Indicator Field Facility universes have been migrated into ICIS for: Muni CSO and SSO sub-NEIs All NSR sub-NEIs All Mineral Processing sub-NEIs Muni MS4 sub-NEI facility universe will be migrated shortly No plan at present to migrate CAFO – “Important CAFO” universe to ICIS With rare exceptions, the regions will not be making changes to the NEI universes The universes are generally static once created Generally need approval from the SIT to change the Universe Indicator flag adding or subtracting a facility from a NEI universe When linking an activity to a facility in ICIS, need to be VERY CAREFUL to select the facility/program interest that has been flagged with the NEI If another facility/program interest is selected, the activity at the facility will not correctly appear on the ICIS report for that NEI. If uncertain, please contact Dan Klaus (202/ ).
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New ICIS Data Fields: Controlled/Addressed, No Further Action, and Initiated Action
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Entering Data to Compliance Determination Screen
Detailed instructions on how to enter NEI data to the ICIS compliance determination screen is including in the FY 14 NEI Reporting Guide Currently entering addressed/no further action status data to the ICIS compliance determination screen for these NEIs: Not entering addressed/no further action status data to ICIS for Air Toxics NEI Entered to AFS instead. NSR/PSD – All Mineral Processing - All Municipal – CSO and SSO; MS4 coming to ICIS soon CAFO - All Energy Extraction
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Controlled/Addressed or No Further Action Date to Use in ICIS
Review of NEI data at EOY FY 2013 revealed that it is not always understood what date to enter into the ICIS compliance determination date fields for the date when a facility is considered addressed or controlled, or the date to enter to indicate that a “no further action” determination has been made. This is a bit complicated by the fact that different events are considered addressing actions under the various NEIs. Nevertheless, it is possible to generalize: During a review of NEI data in FY 2013, it became evident that it is not always understood what date to enter into the ICIS compliance determination date fields for the date when a facility is considered addressed or controlled, or the date to enter to indicate that a “no further action” determination has been made. This is a bit complicated by the fact that different events are considered addressing actions under the various NEIs. Nevertheless, it is possible to generalize: A facility is considered “addressed” (or “controlled” for the NSR/PSD NEI) under the NEIs on the date that the addressing action occurs. For example, if a facility is considered addressed on the date that an enforcement case is concluded resolving the NEI violations at the facility, then the addressed date is the date the judicial consent decree is entered or administrative consent agreement is issued concluding the case. If the event that is considered the addressing action is filing of the complaint, then the addressed date is the date the complaint was filed. The date to enter to ICIS to record a determination that no further action is required at a facility is the date that the region made the determination that no further action at the facility is warranted. If you have questions about this, please contact Dan Klaus (202/ ) or a member of the relevant NEI SIT.
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Controlled/Addressed or No Further Action Date to Use in ICIS
A facility is considered “addressed” (or “controlled” for the NSR/PSD NEI) under the NEIs on the date that the addressing action occurs. For example: When a facility is considered addressed on the date that an enforcement case is concluded resolving the NEI violations at the facility, then the addressed date is the date the judicial consent decree is entered or administrative consent agreement is issued concluding the case. If the event that is considered the addressing action is filing of the complaint, then the addressed date is the date the complaint was filed. The date to enter to ICIS to record a determination that no further action is required at a facility is the date that the region made the determination that no further action at the facility is warranted. If you have questions about this, please contact Dan Klaus (202/ ) or a member of the relevant NEI SIT.
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NEI Addressing Action and No Further Action Types in ICIS
The tables below from the FY 14 NEI Reporting Guide identify the events that determine that a facility has been “addressed” (or “controlled’ for the NSR/PSD NEI) or that “no further action” is required at a facility. Taken from the NEI strategies. Tables are current in ICIS as of January 2014. They can be found in the “Facility Addressed/Controlled Action Type” and the “Facility No Further Action Type” drop-down menus on the ICIS FE&C Compliance Determination Screen. This is valuable because the events that constitute addressing actions and no further actions vary across the NEIs.
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NEI Addressing Action and No Further Action Types in ICIS – NEI by NEI
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NEI Addressing Action and No Further Action Types in ICIS – NEI by NEI
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NEI Addressing Action and No Further Action Types in ICIS – NEI by NEI
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FY 14 NEI Reporting – NEI by NEI
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Municipal NEI: FY 2014 Reporting
For FY 2014, Muni CSO and SSO NEI reporting remains mostly the same as in FY13. Enter to ICIS: Addressed/No Further Action Status NEI Enforcement Initiations (“Initiated Actions”) Federal Inspections Federal Enforcement Actions Green Infrastructure (as element of settlement) Integrated Planning (as element of enforcement case) New ICIS Muni Spreadsheet Report for examining the status of the CSO and SSO NEI universes
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Municipal NEI: FY 2014 Reporting
Municipal NEI Enforcement Initiations (“Initiated Actions”) Unique to the Municipal NEI Must also manually input to ICIS CSO and SSO NEI enforcement action initiations that occurred after mid-November 2012 This includes enforcement actions taken by a state that qualify as an Initiated Action under the Municipal NEI For recording the type of enforcement action and the date that the action was initiated that eventually will address the CSO or SSO Allows us to report to the public not just the number of CSO and SSO facilities addressed, but also the number of facilities in the process of being addressed
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Municipal MS4 NEI: FY 2014 Reporting
MS4 NEI Reporting for MY FY14: For MY FY 14 (as in FY 13), MS4 data will come from the Muni Quickplace MS4 spreadsheet The regions are responsible for: assuring that their MS4 NEI spreadsheet is timely updated reviewing the spreadsheet for accuracy and completeness as part of the FY14 MY data certification process.
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Municipal MS4 NEI: FY 2014 Reporting
For all of FY 14 (MY and EOY): MS4 inspections and enforcement actions should be input to ICIS Each MS4 inspection and enforcement action entered to ICIS must be flagged with the appropriate “WW-MS4” flag in the ICIS “OECA National Priority” data field The MS4 inspection and enforcement data in ICIS will be reviewed and part of the FY14 MY and EOY data certification process Regions also must enter Green Infrastructure and Integrated Planning information to ICIS for MS4 cases where applicable (see below).
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Municipal MS4 NEI: FY 2014 Reporting
Key MS4 facility definitions: Primary Permittee – The MS4 permittee that is designated by the Regions as the permittee that represents the entire “System” for tracking purposes for the MS4 universe spreadsheet and in the ICIS database. The Primary Permittee must have a NPDES permit. The Primary Permittee may be a single permittee without any Co-Permittees, or a permittee with Co-Permittees. Co-Permittee – All of the MS4 permittees/entities that are part of an MS4 “System” that are not the Primary Permittee. Not all Co-Permittees necessarily have their own NPDES permit. System – The MS4 Primary Permittee plus all of the Co-Permittees associated with that Primary Permittee.
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Municipal MS4 NEI: FY 2014 Reporting
MS4 NEI Reporting for EOY FY 2014: For EOY FY14, all MS4 NEI data will come from ICIS MS4 phase 1 universe and addressed/no further action data for the MS4 phase 1 facilities will be migrated to ICIS in the next month or so. The MS4 universe created in ICIS will include links in ICIS between the MS4 phase 1 primary permittees and their related co-permittees. A new ICIS Muni MS4 Spreadsheet Report will be written and posted and will : List all of the MS4 systems in the MS4 phase 1 universe Display for each system the primary permittee and all of the co-permittees associated with the permittee Display separately the status of each MS4 system, the primary permittee, and the co-permittees.
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Municipal MS4 NEI: FY 2014 Reporting
Following migration to ICIS of the data in the MS4 NEI Quick Place spreadsheets, the regions will: cease using the Quick Place spreadsheets. report all NEI addressing action activities to ICIS and The procedures for reporting MS4 NEI data to ICIS are generally the same as for CSOs and SSOs as described above – but, there are some differences:
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Municipal MS4 NEI: FY 2014 Reporting
When the MS4 data is migrated to ICIS from the Quick Place spreadsheets, each MS4 Phase 1 facility in the universe will have been flagged in ICIS (via the Universe Indicator field of the Facilities screen) as either an “MS4 Phase 1 Primary Permittee” or “MS4 Phase 1 Co-Permittee.” Note that there will rarely be any need (as with the other NEIs) for a region to add, delete, or make a change to an NEI flag. Each MS4 “Co-Permittee” that does not have an NPDES permit will have an “unpermitted facility” NPDES permit interest created for it in ICIS as part of the data migration. Assigning a permit # will allow that Co-Permittee to be associated in ICIS with the Primary Permittee.
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Municipal MS4 NEI: FY 2014 Reporting
Then, each Co-Permittee will be associated in ICIS (via the "Associated NPDES Permits" functionality in the ICIS-NPDES "NPDES Permits" module) with a Primary Permittee. This will allow us to write an ICIS report that lists the MS4 Phase 1 “Systems”(grouping the Primary Permittee + Co-Permittees together in the report).
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Municipal MS4 NEI: FY 2014 Reporting
For an MS4 System to be considered addressed the Primary Permittee and each associated Co-Permittee must be flagged in ICIS with one of the addressing action or no further action types. Note in particular the no further action type, “Co-Permittee, No Action Taken” (shaded green in the table below). This type is to be used to flag Co-Permittees that are part of a System that has been determined to have been addressed or for which no further action is warranted for which no compliance assessment was made.
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Municipal MS4 NEI: FY 2014 Reporting
Addressing action types and no further action types for the MS4 NEI are:
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Municipal MS4 NEI: FY 2014 Reporting
The “System Addressed” and “System No Further Action” types (highlighted in the table in pink) are to be used to indicate that an MS4 System, in its entirety, has been addressed or that it has been determined that no further action is warranted. This is done by creating a separate Compliance Determination record in ICIS, linked to the Primary Permittee, flagged with either the “system addressed” or “system no further action.” This enables us to distinguish between instances where the Primary Permittee has been addressed but the System is not yet considered addressed.
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Municipal MS4 NEI: FY 2014 Reporting
MS4 NEI Compliance Determination Data Entry Examples: Primary Permittee with No Co-Permittees: An administrative compliance order (addressing action) is issued to address a MS4 Phase 1 Primary Permittee that has no Co-Permittees. After entering the enforcement action record into ICIS the user will enter a compliance determination record for the facility selecting both “MS4 – Phase 1 - Federal Final Administrative Compliance and Penalty Orders” as the addressing action type, and “MS4s- Phase 1 – System Addressed” to show that this System now is considered addressed.
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Municipal MS4 NEI: FY 2014 Reporting
Primary Permittee with Numerous Co-Permittees: In this case the Primary Permittee and Co-Permittees making up an MS4 Phase 1 System are addressed via three different mechanisms: The Primary Permittee and two Co-Permittees are addressed through filing of a civil judicial complaint (w/o a CD). To record this, a Compliance Determination record is created in ICIS that is linked to these three entities and the appropriate addressing action type is selected. Five more Co-Permittees are addressed by a determination that they have “no or minor violations.” To record this, a second Compliance Determination record is created linked to these five entities and the appropriate no further action type is selected.
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Municipal MS4 NEI: FY 2014 Reporting
Four more very minor Co-Permittees have “no action taken.” To record this, a third Compliance Determination record is created linked to these five entities with the “Co-Permittee, No Action Taken” type selected. Finally, when it is appropriate to indicate that the MS4 “System” as a whole is considered addressed, it is necessary to return to the Compliance Determination that includes the Primary Permittee and add the “MS4s- Phase 1 – System Addressed” addressing action type to this record. This must be done whether the Primary Permittee does or does not have Co-Permittees (see example 1, above).
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Municipal MS4 NEI: FY 2014 Reporting
Once the migration of the MS4 data to ICIS has been completed, to create a Compliance Determination record in ICIS for a MS4 NEI primary permittee, co-permittee, or system that is addressed, or for which no further action will be taken, or against which an action has been initiated, follow the data entry procedures set forth in the NEI Reporting Guide for CSO/SSO Be sure to select the applicable MS4 initiated action, addressing action, or no further action type.
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Municipal MS4 NEI: FY 2014 Reporting
Recent changes made to the addressing action types in ICIS for the Municipal NEI. Municipal Infrastructure NEI – MS4: New Facility Addressed/Controlled Action Type were added: “MS4s-Phase 1-System Addressed” “MS4s-Phase 2-System Addressed” New Facility No Further Action Types were added: “MS4s-Phase 1-System No Further Action” “MS4s-Phase 2-System No Further Action” “MS4s-Phase 1-Co-Permittee, No Action Taken” “MS4s-Phase 2- Co-Permittee, No Action Taken” Facility Addressed/Controlled Action Type was removed: “Provide MS4 Permit Feedback” Municipal Infrastructure NEI: Facility Addressed/Controlled Action Type was modified/clarified: “Federal AOs (AO, ACO, AOC, CAFO, FAPO)” changed to “Final Federal Admin Penalty or Compl Order”
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Municipal NEI: FY 2014 Reporting
Green Infrastructure (GI) For reporting in FY 2013 and beyond, GI data is to be reported into ICIS. Note: Regions may choose to enter their pre-FY13 GI data into ICIS so that all the GI information (previously manually recorded in the spreadsheet) is available electronically for future reporting and analysis.
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Municipal NEI: FY 2014 Reporting
Two reporting options for GI: Where GI is encouraged through the enforcement action settlement select in ICIS the complying action “Green Infrastructure Enabling Language” Where GI is a requirement of the settlement, select in ICIS either the complying action: “Green Infrastructure Requirement (Value Unknown)” When the $ value of the GI component of the injunctive relief is not known at the time of settlement When later the GI value becomes known, can enter a new final order in ICIS to capture the GI value in the FY when the value becomes known “Green Infrastructure Requirement (Value Known)” When the $ value of the GI component of the injunctive relief is known at the time of settlement Note: These two choices replaced the former complying action type, “Green Infrastructure Cost Estimate”
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Municipal NEI: FY 2014 Reporting
Integrated Planning (IP) Reporting for Municipal Cases Beginning FY 2014, regions are requested to report in ICIS enforcement case conclusions which EPA determines to have IP remedies consistent with EPA’s Integrated Municipal Stormwater and Wastewater Planning Approach Framework. Most of the cases would be municipal NPDES CSO, SSO and MS4 enforcement cases initiated by EPA. The threshold for this “IP bean” is not the submission of a plan by a defendant, but rather a determination by EPA that the conclusion meets the intent of the Integrated Plan Framework (with or without a plan). The Regions should input the data into ICIS for any cases concluded during FY 2014 that have IP remedies consistent with EPA’s Framework. In some cases both GI and IP will be triggered and both should be flagged in ICIS (separate data fields). By using this approach, EPA will have a comprehensive count of cases involving IP, as well as a separate stand-alone count of green infrastructure initiated and concluded actions.
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Municipal NEI: FY 2014 Reporting
Integrated Planning ICIS Data Entry The “Integrated Planning Element” indicator has been added to the Administrative Formal Enforcement Action/Initiation Sub-Activity Screen, under the Sub-Activity Type data field. Once the IP determination is made and the case conclusion is flagged as such, the regions must select the “Integrated Planning Element” indicator from the drop down menu. For questions regarding IP reporting or the National Municipal Infrastructure Compliance and Enforcement Strategy contact Amy Porter ( ), or Seth Heminway ( ),
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CAFO NEI: FY 2014 Reporting No immediate changes in CAFO NEI reporting from FY 2013 Report as you did in FY13 Could be reporting changes once decisions are made about any redirection of the CAFO NEI
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CAFO NEI: FY 2014 Reporting EPA and State “Important CAFO” NEI Reporting: The plan to migrate Important CAFO NEI data to ICIS on hold Pending this migration, Important CAFO NEI data is reported as follows: Addressed/no further action determinations, enforcement actions and inspections at Important CAFOs are reported to the QuickPlace spreadsheets EPA inspections and enforcement actions at Important CAFOs must also be reported to ICIS State activities at Important CAFOs must be reported to the QuickPlace spreadsheets and to ICIS as well EPA and State Non -”Important” CAFO NEI Reporting Facility addressed and no further action determinations are reported to ICIS All inspections and enforcement actions are reported to ICIS Full count of EPA “C/AFO Addressing Actions”– Reported to ACS Annual CAFO NEI Progress Report -- Reported manually
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CAFO NEI: FY 2014 Reporting EPA CAFO NEI Inspections and Enforcement Actions Concluded EPA inspections, enforcement actions: Enter inspections into ICIS-NPDES (flag as “WW-CAFO” or “WW-CAFO Regional Initiative Areas”) Enter enforcement actions into ICIS (flag as “WW-CAFO” or “WW-CAFO Regional Initiative Areas”) EOY certification via OECA’s standard data certification process, as in FY2012 and 2013
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CAFO NEI: FY 2014 Reporting One change to ICIS to clarify an existing CAFO NEI Addressing Action Type. CAFO NEI Facility Addressed/Controlled Action Type was modified/clarified in ICIS: “Federal AOs (AO, ACO, AOC, CAFO, FAPO)” changed to “Final Federal Admin Penalty or Compl Order”
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NSR/PSD NEI: FY 2014 Reporting
No change in reporting from FY 2013 Enter to ICIS: Investigation initiations Enforcement actions, Controlled/no further action determinations New “NSR/PSD NEI Spreadsheet Report” in ICIS for examining the status of the NSR/PSD NEI universes (CFPP, Cement, Acid, Glass)
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NSR/PSD NEI: FY 2014 Reporting
Reminder: NSR/PSD NEI Investigation initiations Input to ICIS all NSR/PSD NEI investigations initiated Input investigations to ICIS as an “Investigation,” not as and “inspection.” Any questions about whether a particular NSR investigation qualifies as an “investigation initiation” for purposes of the NSR/PSD NEI should be directed to Shaun Burke, OCE/AED (202/ )
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Air Toxics NEI: FY 2014 Reporting
Air Toxics NEI Enforcement Action Data No change in reporting from FY 2013 All Air Toxics NEI enforcement actions must be entered into ICIS and properly flagged as part of the Air Toxics NEI Air Toxics NEI inspections and addressing actions must be entered into AFS and must be properly flagged as part of the Air Toxics NEI
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Mineral Processing NEI: FY 2014 Reporting
No change to reporting from FY 2013 Enter to ICIS: Inspections Enforcement actions, Addressed/no further action determinations New ICIS Mineral Processing Spreadsheet Report for examining the status of the 2 Mineral Processing NEI universes Phosphoric Acid and Non-Phosphoric Acid
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Energy Extraction NEI: FY 2014 Reporting
No change in EE NEI reporting from FY 2013 All data for the Energy Extraction (EE) NEI is obtained from ICIS Regions must assure that all FY14 EE NEI inspections/ evaluations and enforcement actions are entered into ICIS and are properly flagged with the EE NEI flag All facilities subject to an EE NEI inspection or enforcement actions should be flagged in ICIS as an EE NEI facility.
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NEI Reporting CHEAT SHEETS
FY 2014
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FY14 NEI Data Reported to ICIS
Enforcement Actions All NEIs Also report MS4 and Important CAFO NEI enforcement actions to the respective Quickr Spreadsheet Investigation Initiations NSR/PSD (CFPP, Cement, Acid (Nitric and Sulfuric), Glass) Inspections/Evaluations Mineral Processing - All Municipal – All Also report inspections at MS4s to the MS4 Quickr Spreadsheet Energy Extraction - All CAFO - All Also report NEI inspections at Important CAFOs to the Important CAFO Quickr Spreadsheet Facility Universe Indicator (rarely to be manually populated) NSR/PSD – Coal-Fired Power Plants (CFPP), Cement, Acid (Nitric and Sulfuric), and Glass Mineral Processing - Phosphoric Acid and Non-Phosphoric Acid Municipal – CSO and SSO (and MS4 following MS4 data migration to ICIS) Addressed/ No Further Action Determinations NSR/PSD - All Mineral Processing - All Municipal - CSO and SSO (and MS4 following MS4 data migration to ICIS) Energy Extraction – All CAFO -- All
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FY14 NEI Data Reported to AFS or ACS
Inspections/Evaluations Air Toxics (data input to AFS) Addressing Actions CAFO - full count of CAFOs addressed (data is input to ACS (OCFO) data system)
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FY 14 NEI Data Manual Reported (i.e., not reported to a data system)
Universe Municipal - MS4 Report to manual MS4 Quickr Spreadsheet until data is migrated to ICIS CAFO - Important CAFOs Report to manual Important CAFO Quickr Spreadsheet until data is migrated to ICIS (which may or may not occur in FY14) Addressed/No Further Action Determinations Municipal - MS4 Enforcement Actions Report to manual MS4 Quickr Spreadsheet until data is migrated to ICIS; must also be input to ICIS Report to manual Important CAFO Quickr Spreadsheet until data is migrated to ICIS (which may or may not occur in FY14); must also be input to ICIS Inspections/Evaluations CAFO NEI Annual Report - Must report to the CAFO SIT: Changes in priority areas (addition of new areas) Narrative on activities to strengthen state programs State data (as available), and Attached name list of facilities addressed (for C/AFOs not identified as “important CAFOs”)
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NEI Reporting -- NEI Reports
FY 2014
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ICIS Reports for Use When Reviewing Data for All NEIs
Certification National Enforcement Initiative Case Counts FY FY 2013 National Enforcement Initiative Environmental Benefits DQR - Initiated and Concluded National Initiative cases All
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Additional ICIS Reports for Reviewing CAFO, Energy Extraction, and Municipal Infrastructure NEI Data
Energy Extraction NEI: FY FY2013 Initiative Inspections Report NEI Compliance Determination report CAFO NEI: Total # Wet Weather Inspections Total # CAFO Joint Inspections DQR - National Initiative & Program QA Municipal Infrastructure NEI: Municipal NEI Spreadsheet report
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Mineral Processing NEI:
Additional Reports for Reviewing Mineral Processing, NSR/PSD, and Air Toxics NEI Data Mineral Processing NEI: FY FY2013 Initiative Inspections Report Mineral Processing NEI Spreadsheet report NSR/PSD NEI: NSR-PSD NEI Investigations report NSR-PSD NEI Spreadsheet report DQR - National Initiative & Program QA Air Toxics NEI: AFS Air Toxics Addressed/No Further Action Report AFS Air Toxics Evaluations Report
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NEI Compliance Determination Report
Provides counts of facilities with addressed or no further action determination Generally used for NEIs without a universe Defaults to run for Energy Extraction NEI only Can be run for any NEI (except Air Toxics) “Details By Facility” tab shows the latest determination information for each facility “Details By Activity” tab shows all determinations at each facility
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Municipal NEI Spreadsheet report
Best to run by sub-initiative & save results in Excel “By Facility” tab shows all facilities in the universe (e.g., CSOs >= 50K serv. pop'n.) and, for each facility, their: Identification and location information Addressed/Controlled, No Further Action, or Initiated Action status Most recent inspection/evaluation or investigation Most recent enforcement action Referral Admin/Judicial Complaint Final Order Lodged Final Order
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Municipal NEI Spreadsheet report
For all tabs (except “QA Report #1”) the ICIS National Enforcement Sub Initiative Flag (which is derived from the “National Priority” flag) must equal the Facility NEI Universe Indicator for the activities to be counted/shown
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Municipal NEI Spreadsheet report
Provides counts of facilities, in the sub-universe selected, with: an addressed or no further action or initiated action determination initiated but not yet concluded enforcement actions an inspection/evaluation or investigation For each, there are crosstabs showing the counts by sub-initiative and fiscal year, and by sub-initiative and region
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Municipal NEI Spreadsheet report
Initiated but not yet concluded for the municipal NEI means there is an Initiated Action determination, but no: Addressed/Controlled determination, and No Further Action determination For the Mineral Processing and NSR/PSD NEIs the definition of “initiated but not yet concluded” is different
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Municipal NEI Spreadsheet report
In the “Facilities Inspected by Date” tab, if a facility was inspected in multiple years, it is counted in each year it was inspected Therefore, the counts can be higher than in the “Facilities Inspected by Region” tab The “Facilities Inspected by Date QA” tab can be used to identify the facilities that are being counted multiple times so you can manually adjust the counts in the “Facilities Inspected by Date” tab, if desired.
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Municipal NEI Spreadsheet report
“By Activity” tab shows all activities at each facility (e.g., not just the most recent) “QA Report #1” tab shows all activities where the National Enforcement Sub Initiative flag does not equal the NEI Facility Universe Indicator, or is null Limited to “CWA” activities that occurred since 10/1/2000 If you think there should be activities at a facility on the “By Facility” tab, you can check the “QA Report #1” tab to see if they are there
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Recent Updates to the Report
Added the “Facilities Inspected” and “Initiated Not Concluded” crosstabs Show & use the “National Enforcement Sub Initiative Flag” from both the initiation and final order screens Older CSO enforcement actions and inspections are now shown/counted Added additional optional date prompts to the enforcement action query Restricted activities shown on “QA Report #1” and removed repeating headers Removed “QA Report #2”
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Future Planned Updates
These same updates will be made soon to the Mineral Processing and NSR/PSD NEI spreadsheet reports Add a new QA tab that looks at facilities addressed with EA (according to the compliance determination universe) but no NEI flagged EA (according to the enforcement action universe). And, vice versa. Add a new QA tab to show instances of activities flagged as a NEI, but the facility is not in the NEI universe
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Reliability of the ICIS NEI Reports
The reliability of these NEI reports depends on: Linking ICIS records to the facility that is flagged with the correct NEI universe indicator Creating the compliance determination records in ICIS following the data migration For all addressed/controlled and no further action determinations For all enforcement actions initiated Entering and flagging NEI inspections/evaluations, investigations, and enforcement actions in ICIS with the NEI “National Priority” flag Conducting a thorough DQ review of the NEI data (training coming!)
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The End
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