to: roger janson/r1/usepa/us@epa, lucy casella…€¦ · web viewnotice of new and changed...

Notice of New and Changed Enforcement and Compliance Data Reporting and Certification Requirements for FY 2013

This document is intended to provide notice to the Regions and OECA offices regarding FY 2013 Federal enforcement and compliance data. In particular, this document addresses: new enforcement/compliance data reporting requirements; changes to reporting requirements; and reporting that proved problematic (identified in italics) in FY 2012.

The FY 2013 Reporting Plan will contain a complete description of all new and changed FY 2013 enforcement/ compliance reporting requirements.

CONTENTS

Data Quality Reviews and Certification Process1. OECA Suite of Measures Summary (OSMS Dashboard) Version 2.02. Accessing OECA Suite of Measures Summary3. Certification Process Change: Reduced ICIS Preliminary Data Pull4. Certifying the Data

Environmental Justice5. ICIS Environmental Justice Reporting: Transition to EJSCREEN and Changes to ICIS Data

Fields

National Enforcement Initiative (NEI) Reporting6. Summary of FY 2013 NEI Reporting7. Tracking Municipal NEI Green Infrastructure Settlement Information 8. Changes to Addressing Action Type and No Further Action Type Lists on the ICIS Compliance

Determination Screen

Clarification of Case Conclusion Environmental Benefits Reporting in ICIS 9. Entering Hazardous Waste, Hazardous Material/Substances and VCMA Amounts10. Avoid Double Counting of Environmental Benefits11. Reporting Outcomes from CWA, CSO, and SSO Enforcement Actions

Reminders12. Reminder: Continue to Enter Big Case Projection Data13. Reminder: Supplemental Environmental Project (SEP) Reporting

1Early Notice of New and Changed Reporting Requirements

for FY 2013 Enforcement and Compliance Data

Attachments

FY 2013 Key Reporting Dates FY 2013 State Reporting Schedule FY 2013 Government Performance and Results Act (GPRA) Measures FY 2013 Enforcement and Compliance Assurance Reporting Contacts (Excel file) NEI Initiative, Sub-Initiative and Action Lists



DATA QUALITY REVIEWS AND CERTIFICATION PROCESS

1. OECA Suite of Measures Summary (OSMS Dashboard) Version 2.0The second version of the OECA Suite of Measures Summary (OSMS) Dashboard has been released and is currently available at the following link: http://intranet.epa.gov/oeca/oc/index.html The Dashboard consolidates enforcement and compliance measures from multiple OECA sources, and presents the data in a tabular or graphic format. This allows users to easily view trends and conduct other analysis or comparisons of interest. Significant new features in the Dashboard include:

- daily updates of FY 13 ICIS data,- the ability to drill down to FY 13 case level information,- the ability to export data to Excel,- a breakout of Federal Facilities data, - enhanced National Enforcement Initiation (NEI) data displays, and- Consent Decree tracking data displays.

Currently, the Dashboard contains seven (7) years of civil enforcement outputs and outcomes broken out by region and program. Criminal, CERCLA, National Enforcement Initiatives measures, as well as FY12 ACS targets and results are also available.

In FY 13 the Dashboard will continue to be a critical tool used for conducting the AA/Regional video conference meetings. The Dashboard will be used again this year to facilitate discussions on the civil, Superfund, and Criminal enforcement programs, and provide the ability to quickly obtain regional program-specific data. The Dashboard also can be used as a tool for on-going data quality review.

2. Accessing OECA Suite of Measures Summary OSMS is now available thru the intranet under the Quick Resources section at the following link: http://intranet.epa.gov/oeca/oc/index.html



http://intranet.epa.gov/oeca/oc/index.html

http://intranet.epa.gov/oeca/oc/index.html

At the BUSINESSOBJECTS INFOVIEW screen, double click on the OSMS Dashboard (shown below circled in brown) located under “Title.”

3. Certification Process Change: Reduced ICIS Preliminary Data Pull In FY 13, the OECA Suite of Measures Summary (OSMS) Dashboard will take on new significance during the MY and EOY data certification processes. In an effort to further streamline the data certification process, OC is incorporating the OSMS Dashboard as an integral component of the MY and EOY data quality reviews.

Beginning with the MY 2013 data certification process, OC will no longer run and post the full set of preliminary ICIS certification reports. Regional Program Managers and Enforcement Coordinators should utilize the OSMS Dashboard to assist with ensuring that their ICIS data is complete and accurate. Since the enhanced OSMS Dashboard includes the ability to access current



FY 13 ICIS data and the ability to drill down to case-specific information much of the data quality review can be completed via the Dashboard instead of reviewing each ICIS report.

By relying more on the OSMS Dashboard for data quality review, the HQ and regions will save precious staff hours scheduling, posting, and reviewing numerous ICIS reports to conduct the MY and EOY data quality reviews. However, if more detailed action-specific data is desired, all ICIS reports are still available and regions may run and review any specific ICIS reports that may contain data requiring more scrutiny.

During the MY and EOY 13 certification processes, OC will continue to run preliminary AFS and RCRAInfo reports and post them to the Data Depot. Also during the MY and EOY processes, OC will continue to run and post the full final set of ICIS certification reports. This final set of ICIS certification reports will be used to populate the Excel certification files.



4. Certifying the Data In FY 2013, OECA will continue with the streamlined process that was conducted in FY 2012. As was done in FY 2012, certification workbooks will not be exchanged back and forth between OC and Regional Offices. The streamlined process that was established in FY 2012 will continue to allow OECA to maintain a high level of data quality while decreasing the time and resources needed to certify our enforcement and compliance data.

No later than April 19, 2013, Regional DRAs, OCE Office Director and OC Division Directors will certify to the accuracy and completeness of mid-year (MY) data into the national databases of record. For EOY, Regional DRAs, OCE Office Directors and OC Division Directors will certify no later than October 23, 2013.

ENVIRONMENTAL JUSTICE

5. ICIS Environmental Justice Reporting: Transition to EJSCREEN and Changes to ICIS Data Fields

For the first half of FY 2013, Environmental Justice (EJ) reporting in ICIS is continuing unchanged from FY 2012 adhering to terms of the “Internal Technical Directive: Reviewing EPA Enforcement Cases for Environmental Justice Concerns and Reporting Findings to the ICIS Data System” (the EJ Technical Directive). OECA and the Regions are reviewing the FY 2012 pilot of the EJ Technical Directive and are considering changes.

In addition, the Agency’s new EJ screening tool, EJSCREEN, has recently been released and will replace EJSEAT, including its use for screening and reviewing cases as required by the EJ Technical Directive. Following the review of the pilot, a revised EJ Technical Directive will be released effective April 1, 2013.

Exactly how the EJ Technical Directive will be revised is currently being determined. Still, some things are now clear, particularly as to use of EJSCREEN and changes to the ICIS data fields. These changes will be effective on April 1, 2013, along with additional changes to the EJ Technical Directive, yet to be decided:

Most important, the basic review under the EJ Technical Directive will be done, starting March 30 using EJSCREEN rather than EJSEAT. An ICIS release scheduled for Friday evening, March 29th will replace the two current EJSEAT Score data fields and replace them with two “EJSCREEN Flag” data fields. The old EJSEAT data fields [EJ Score (auto) and (manual)] will be retained in the ICIS database but will not be displayed on the Enforcement Action screen or available to update. The new EJSCREEN Flag (auto) data field will be automatically populated with “Yes” (meets the threshold requiring an enhanced review), “No” (does not meet the threshold requiring an enhanced review), or “No score” (no score was available to auto-populate this data field) based on the value assigned to the facility. The EJSCREEN Flag (manual) field will have the same “Yes” and “No” options plus the old



“Exempt” and “TEMP.” options. The Yes/No approach is different than the numeric scoring that was provided by EJSEAT but should serve the same purpose of providing a basic EJ screen of our enforcement cases.

EJSCREEN will also be the preferred tool for conducting the enhanced review under the EJ Technical Directive. The “Interim EJSCREEN Common User Guidelines,” Nov. 12, 2012, provides guidance on how to use EJSCREEN for doing an enhanced/additional review. See http://intranet.epa.gov/gis/pdfs/ejscreen-common-user-guidelines.pdf. EJSCREEN is available at http://gisint1.rtpnc.epa.gov/ejscreen/.

As noted above, the shift from use of EJSEAT for the basic EJ review to EJSCREEN will be effective on April 1, 2013. This transition will create some complications for ICIS enforcement action records created prior to April 1 for which the EJ data was not completed prior to April 1 (generally cases for which “TEMP” was selected). It will be helpful if all “TEMP’s” are addressed prior to April 1.

For any case record created in ICIS prior to April 1 for which an EJSEAT score auto-populated or the region entered a manual value (1-10, Exempt, or TEMP) in the EJSEAT Score (manual) field, the old EJSEAT fields and business rules will still meet the requirement for populating the EJ data in ICIS. The old EJSEAT Score fields (auto and manual), however, will not appear on the screen (having been replaced by the new EJSCREEN Flag fields (auto and manual)). It will not be possible to enter any data to the old EJSEAT score fields. Therefore, if an EJ “score” needs to be entered for such an enforcement record, it must entered into the EJSCREEN Flag (Manual) field with a value of “Yes”, “No”, “TEMP.”, or “Exempt.” Note, if a value is entered to the EJSCREEN Flag (Manual) field, then the applicable business rules for the other EJ data fields will be in force.

Note: the EJSCREEN Flag (Auto) will not auto-populate for ICIS enforcement action records created prior to April, so the EJSCREEN score will have to be obtained manually and entered to the EJSCREEN Flag (manual) field.

For any ICIS case record created after March 31, including cases initiated prior to April 1, the EJ analysis, basic, and enhanced, will have to be done using EJSCREEN and not EJSEAT. The EJSEAT score data fields will not be available to populate and, as a matter of policy, we will have transitioned to using EJSCREEN for our EJ reviews.

The labels and business rules for some of the EJ data fields will change as well.

The label on the “Additional Review for Potential EJ Concerns” will be changed to “Enhanced Review for EJ Concerns” to track the terminology used in the EJ Technical Directive. The business rules for this field will also change, requiring that the field be



http://gisint1.rtpnc.epa.gov/ejscreen/

populated for all cases unless “Exempt” or “Temp” is selected in the EJSCREEN Flag (manual) field.

The selections in the pull down menu will also change, to: Additional Enhanced Review – Potential EJ Concern Found Additional Enhanced Review – Potential EJ Concern Not Found No Additional Enhanced Review

The pull down menu for the “Basis of EJ Determination” data field will change to: Reviewed using EJSCREEN Public input Community self-identification EPA knowledge of community/location (including inspector observation) Other federal government knowledge of community/location State/local government knowledge of community/location Other basis (explain in Explanation of Basis field)

The label on the “Explanation of Basis for Potential EJ Concern Finding or Exemption from EJ Review” is changing, to add the word “potential.”

New reports will be posted in ICIS making use of the new EJSCREEN Flag data fields and will be used to pull the EJSCREEN-based EJ data from ICIS at mid-year and end-of-year certification. The old EJ reports will be retained to pull the EJSEAT-based EJ data from ICIS at mid-year and at end-of-year.

Other significant aspects of the EJ Technical Directive that may change based on the review of the pilot are the required timing of the review for potential EJ concerns (basic and enhanced) and the cases that are exempted from the EJ review requirement. These decisions should be made by the time the FY 2013 Reporting Plan is released and will be captured there – and in the Revised EJ Technical Directive.

Training on the changes to the EJ technical Directive and on using EJSCREEN for EJ screening and review purposes will be developed and scheduled for later this year.

NATIONAL ENFORCEMENT INITIATIVE (NEI) REPORTING

6. Summary of FY 2013 NEI ReportingNational Enforcement Initiative reporting to ICIS which began in FY 2012 and earlier will continue in FY 2013. In addition, we will continue to migrate NEI data into ICIS to better assure the quality of the data, and to make the data more accessible. Universe and addressing action data for CSOs, SSOs, important CAFOs, and coal fired power plants through FY12 will be imported into ICIS. ICIS will become the official database for tracking the CSO and SSO sub-initiatives starting at mid-



year. All FY13 addressing actions and no further action determinations for these facilities will have to be entered into the ICIS Compliance Determinations module in accordance with the “Muni NEI Supplemental Addressing Action Guidance for CSOs and SSOs” expected to be finalized in March 2013. Supplemental guidance relating to tracking MS4s will also be finalized later this year.

All FY 13 addressing actions and no further action determinations for these facilities will have to be entered into the ICIS Compliance Determinations module in accordance with the “Muni NEI Supplemental Addressing Action Guidance for CSOs and SSOs” which is expected to be finalized in March 2013. This guidance will clarify the process, definitions, and underlying principles that support facility, program and situation specific addressing action determinations. Supplemental guidance relating to tracking MS4s will also be finalized later this year.

When creating a compliance determination record in ICIS, the user will have to make sure that the facility linked to that compliance determination is part of the correct NEI universe. Facilities that are part of an NEI universe for which there presently is no facility record in ICIS will have an ICIS facility record created during the data migration.

By mid-year, all NEI data addressing and enforcement action data, except for Muni/MS4s, should be entered and tracked in ICIS. Discussions are continuing about capturing unit and megawatt information for NSR Coal Fired Power Plants, and about how ICIS can be adapted to capture MS4 data, probably in FY 2014. MS4 data will continue to be tracked using the Regional spreadsheets posted on the Muni-Data Quickr for EOY 2013 reporting.

Associated ICIS reports will be written and posted, and we are working on modifications to the ICIS/OSMS Dashboard to allow for regional and SIT tracking of NEI activities and progress. Detailed guidance will be provided to the regions prior to mid-year for entering data into ICIS for each of the initiatives.

7. Tracking Municipal NEI Green Infrastructure Settlement InformationThe National Municipal Infrastructure Compliance and Enforcement Initiative Strategy states that “EPA will evaluate in every case, and where appropriate ensure green infrastructure (GI) remedies are implemented to reduce discharges of raw sewage and reduce pollutants in storm water runoff.” Recent revisions to the strategy require tracking of: a) enforcement cases requiring GI remedies and the estimated value of those remedies, and b) cases with provisions (also referred to as “enabling language”) for the exploration and inclusion of GI remedies which are not legally required in the case settlement.

In FY2012, the regions were asked to manually report CSO, SSO, and MS4 GI information in the comment field of the appropriate Quickr spreadsheet. For reporting in FY 2013 and beyond, Headquarters is implementing a process for regions to track GI data in ICIS. Following are guidelines for entering the data into ICIS. (In addition, regions may choose to enter their FY2012 GI data in ICIS so that GI information previously manually reported is available electronically for future reporting and analysis.) EPA will report annually both the number and percentage of federal



enforcement actions where GI is required as part of the remedy, and where settlements/actions include GI enabling language.

Data Entry Instructions:For FY2013, CSO, SSO, and MS4 NEI concluded cases which include GI remedies or “enabling” language the GI information must be entered into ICIS.

For each NEI case conclusion where a green infrastructure remedy is required, enter the Green Infrastructure Complying Action Type (“Green Infrastructure Cost Estimate”) and the estimated remedy value (if available).

For each NEI case conclusion that includes Green Infrastructure “enabling language” (but no required green infrastructure remedy), enter the Green Infrastructure Complying Action Type (“Green Infrastructure Enabling Language”) and $0 for the remedy value.

Rather than establishing a new data entry screen or fields for tracking green infrastructure remedies, HQ will use the data fields on the existing ICIS Complying Action/Injunctive Relief data entry screen. We will add two new complying action types specifically for tracking green infrastructure, “Green Infrastructure Cost Estimate” and “Green Infrastructure Enabling Language.” Following are the required ICIS data entry requirements and the appropriate values that must be entered, all on the Complying Action/Injunctive Relief screen:

o Statute: <select> CWA-Clean Water Acto Law Section: <select> CWA 301/402: NPDES Permit Violations: NPDES-Combined

Sewer Overflows (CSO) or CWA 301/402: NPDES Permit Violations: NPDES-Sanitary Sewer Overflow (SSO) or CWA 301/402: NPDES Permit Violations: NPDES-Stormwater-MS4

o Complying Action Category Type: <select> Reduction of Ongoing Releaseso Complying Action Type: <select> Green Infrastructure Cost Estimate o Units: <select> Dollarso Amount: <enter> Estimated cost for required green infrastructure remedieso Media: Water (navigable/surface)

-OR-o Complying Action Category Type: <select> Reduction of Ongoing Releaseso Complying Action Type: <select> Green Infrastructure Enabling Languageo Units: <select> Dollarso Amount: <enter> “0” o Media: Water (navigable/surface)

(Note: Green Infrastructure information is an internal reporting measure. The data will not be associated with a national measure. A report will be written and posted in ICIS for extracting case data with GI remedies, the value of these remedies, and cases with GI enabling language.



If you have questions regarding the reporting instructions below, please contact Donna Inman, at 202-564-2511, [email protected]. For questions regarding the National Municipal Infrastructure Compliance and Enforcement Strategy, you may contact Amy Porter, at 202-564-2431, [email protected], or Seth Heminway, at 202-564-7017, [email protected].

8. Changes to Addressing Action Type and No Further Action Type Lists on the ICIS Compliance Determination Screen

A recent review of the Addressing Action and No Further Action types listed on the ICIS Compliance Determination screen revealed the need for clarifications and corrections. Most of these are wording changes, but a few of the changes are more significant. All of the changes are listed in the relevant document attached to this memorandum.

The wording changes to the Addressing Action and No Further Action types have been done to clarify them or to make them consistent. For example, the Mineral Processing Addressing Action type "Federal Administrative Orders (AO, ACO, AOC, CAFO, FAPO)" has been changed to add the word "Final" ("Federal Final Administrative Orders...") to clarify that the qualifying Addressing Action must be a final administrative order, not an administrative complaint. The other wording changes serve similar purposes.

The significant changes (more than just wording) are as follows: Added a new Addressing Action type for Air Toxics - Excess Emissions, "Federal civil case

referred to DOJ." This Addressing Action type had been accidentally omitted.

The Energy Extraction (EE) Addressing Action type "No/Minor Violations and region documented operation" is being inactivated in ICIS and the instances when this Addressing Action type was used will be migrated to the existing EE No Further Action type, "No Further Action Determination pursuant to Dec 21, 2011 Memorandum." This is to correct the fact that the "No/Minor Violations and region documented operation" Addressing Action type really described a No Further Action scenario.

The Mineral Processing (MP)Addressing Action type ""No or Minor Violations" is being inactivated in ICIS and the instances when this Addressing Action type was used will be migrated to a new MP No Further Action type, "Federal inspection determined no or minor violations." This is to correct the fact that no No Further Action type had been created for the MP NEI, and the "No or minor violations" Addressing Action type really was a No Further Action type.

All of the wording changes for the addressing action/no further action types have already been implemented in ICIS. The migration of the EE and MP Addressing Actions to No Further Actions, described above, will occur prior to mid-year FY 2013.

If you have any questions about these changes, please contact Dan Klaus [[email protected] or (202) 564-7757].



mailto:[email protected]



CLARIFICATION OF CASE CONCLUSION ENVIRONMENTAL BENEFITS REPORTING IN ICIS

In January 2012, HQ implemented new CCDS guidance that employs a new approach for reporting environmental benefits of concluded enforcement cases. The new approach categorizes environmental benefits based on the type of remedy that must be implemented as a result of the enforcement action, rather than the statutory authority of the enforcement action. The new approach aims to simplify the process for determining how to quantify benefits and improve national consistency in reporting.

9. Entering Hazardous Waste, Hazardous Materials/Substances and VCMA AmountsDuring the FY2012 HQ big case review process, there was a perceived ambiguity regarding how to report “hazardous waste” and hazardous material/substance1 environmental benefit amounts in certain case scenarios. In prior reporting years HQ communicated end-of-year guidance to the regions identifying standard methodologies for calculating benefits from RCRA Subtitle C, RCRA Corrective Action, and CERCLA enforcement cases. However these methodologies were based on prior guidance based on the old statutory authority approach. Under the new reporting structure established in the FY 2012 CCDS, the type and form of waste as it exists in the environment must be taken into account to properly categorize and report “hazardous waste” vs. hazardous waste material/substance environmental benefits.

A specific set of rules exist for entering “hazardous waste” in ICIS so that the amounts are reported separate from other materials and/or substances that do not meet the statutory or regulatory definition of “hazardous waste.” The following guidance is intended to clarify how to quantify and report “hazardous waste”, hazardous materials/substances, and volume of contaminated medium environmental benefits in ICIS. How to Report Different Scenarios to ICIS

“Hazardous Waste” or Listed Hazardous Waste Stream (Pounds)

If a RCRA hazardous waste exists in its original form as it was generated, probably containerized in some way (e.g., drums, roll-off containers, containment areas), such that it is separately identifiable or otherwise distinct from any media (soil or water), calculate the entire mass of the hazardous material in pounds and report the amount to ICIS using the specific hazardous waste name (F001, for example) or the pollutant name “hazardous waste.”

Hazardous Materials or Substances (not deemed RCRA “hazardous waste” by definition) (Pounds)

1 As used herein ”hazardous materials and/or substances” are materials that may contain hazardous or toxic constituents but are not deemed a RCRA “hazardous waste” under the statute or regulations.



For a hazardous material or any other contaminant/substance that is separately identifiable and not a comingled mixture of “hazardous waste”, calculate the mass of the material or substance in pounds and report the specific name of the pollutant and the impacted medium (e.g., air, water, land) in ICIS. Do not report the amount of the material as “hazardous waste.”

Volume of Contaminated Medium –VCMA (Cubic Yards)

For cases where the pollutant (“hazardous waste” or hazardous material/substance) is entrained in traditional media (i.e., soil, sediment, or groundwater aquifer) or if it exists in the form of a contaminated structure or debris (e.g., pieces of wood, cement, decommissioned equipment), estimate in cubic yards the volume of the contaminated medium in which the pollutant exists in the environment and select in ICIS the pollutant name that best describes the medium impacted or manner in which the pollutant exists in the environment (e.g., contaminated groundwater, contaminated soil, contaminated debris, etc.)

Counting Environmental Benefits for Performance Measures Reporting:HQ has established specific reporting measures for capturing environmental benefits from our enforcement cases. The measure that applies depends on the type of remedy that is required by the enforcement action and the nature of the material that is being addressed. Following are the reporting categories under which “hazardous waste”, hazardous materials/substances, and contaminated media are counted.

Type of Material Addressed, Remediated, Cleaned up

Performance Measure in which Benefits are Counted

Applicable Unit

Impacted Medium

Hazardous waste material that meets the regulatory definition of “hazardous waste” and is not mixed with an environmental medium.

“Hazardous Waste Treated, Minimized or Properly Disposed of”

Pounds Land or Soil

Hazardous or toxic materials/substances that:

a) contain hazardous or toxicconstituents,

b) do not meet the regulatory definition of “hazardous waste” and,

Depending on the medium impacted -

“Estimated Toxics and Pesticides Reduced, Treated or Eliminated”

Pounds Land

“Estimated Air Pollutants Reduced, Treated or Eliminated”

Pounds Air



Type of Material Addressed, Remediated, Cleaned up

Performance Measure in which Benefits are Counted

Applicable Unit

Impacted Medium

c) are not mixed with an environmental medium.

“Estimated Water Pollutants Reduced, Treated or Eliminated” Pounds Water

“Hazardous Waste” or other hazardous or toxic materials/substances that have contaminated an environmental medium such as groundwater aquifer, soil or sediment, and structures or debris such as wood, plastic, synthetic material or decommissioned equipment that is contaminated with “hazardous waste” or other hazardous or toxic material/substance.

Depending on the medium impacted –

“Estimated Contaminated Water/Aquifer to be Cleaned Up”

Cubic Yards Water

“Estimated Contaminated Soil/Debris to be Cleaned Up”

Cubic Yards Land or Soil

For questions: Contact Donna Inman, OC/Planning, Measures and Oversight Division, at 202-564-2511, or via email at: [email protected].

10. Avoid Double Counting of Environmental BenefitsAs part of the FY2012 data certification process, HQ observed a number of instances where a given pollutant amount had been reported under multiple complying action types, resulting in double counting of the environmental benefit. For example, an enforcement case involved two different complying actions, namely “Reduction – Abatement (non-removal remediation)” and “Reduction – Implement Asbestos Management Plan”, and both actions were entered in ICIS reporting the same pollutant reduction.

As a reminder, a standard principle in the FY2012 CCDS guidance states that where multiple complying actions may be associated with a single environmental benefit, the pollutant reduction amount(s) should be associated with only one complying action to avoid double counting. If it is deemed necessary to track additional complying actions for a pollutant amount that has already been reported, an amount of “0” must be associated with each additional action.

For questions: Contact Donna Inman, OC/Planning, Measures and Oversight Division, at 202-564-2511, or via email at: [email protected]





11. Reporting Outcomes from CWA, CSO, and SSO Enforcement ActionsFor CWA Combined Sewer Overflow (CSO) and Sanitary Sewer Overflow (SSO) enforcement actions, both the gallons of untreated discharge eliminated, and the pounds of pollutants reduced should be reported to ICIS. This data is entered on the Final Order, Complying Action/Injunctive Relief Screen. The pollutant name to associate with the gallons of untreated discharge eliminated is "Untreated Sewage", "Sanitary sewage", "Wastewater", or "Sanitary waste". The screen shot below shows an example of a correctly entered case.

The ICIS report "National Enforcement Initiative Environmental Benefits" can be used to review the gallons of untreated discharge eliminated, and the pounds of pollutant reduced. The gallons are counted in the metric: "Volume (gallons) of Untreated Discharge Eliminated". The pounds are counted in the metric: "Estimated Water Pollutants Reduced, Treated, or Eliminated (pounds)".

12. Reminder: Continue to Enter Big Case Projection DataRegional and HQ data entry stewards must enter all FY 2013 Big Case data including big case projection data into ICIS. In FY 2013, Big Case Projections will continue to be a helpful case management tool for OC, OCE, OSRE, and DOJ. OC will pull Big Cases Projections data only once in FY 2013. The data will be pulled on April 22, 2013 along with the other MY data final pull.

This Big Case data pull will be conducted to inform discussions held during the Summer Senior Enforcement Managers (SEM) meeting, and to inform the AA/Regional Progress Meetings. In FY 2013, OC will only be collecting data for the current fiscal year (FY 2013). FY 2014 projections data are not being requested at this time.



13. Reminder: Supplemental Environmental Projects (SEP) Reporting In December 2007, OECA issued a memorandum discussing SEPs and the use of the PROJECT model, which directed that the cost of a SEP, and not any PROJECT-generated valuation, should be entered as the SEP value in ICIS. The SEP cost is the minimum amount that must be expended on the SEP by the violator.



to: roger janson/r1/usepa/us@epa, lucy casella…€¦ · web viewnotice of new and changed...

Documents