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Webinar: Conducting a Data Quality Review of National Enforcement

Initiative (NEI) Data at MY and EOY

https://epa.connectsolutions.com/neidqreview/



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DANIEL PALMER,DANIEL KLAUS, ANDDAVID SPRAGUE, OC

MARCH 31 , 2014

Webinar: Conducting a Data Quality Review of National

Enforcement Initiative (NEI) Data at MY and EOY

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What is this Training All About?

Over the past few years we have been coming to rely much more on the national data systems, primarily ICIS, to track the National Enforcement Initiatives (NEIs) In FY11 we added data fields to the ICIS Facility and

Compliance Determination modules that allow us to: Identify the facilities that are part of an NEI universe, e.g.,

NSR/PSD cement plants Create a record in ICIS showing that a facility has been

“controlled” or “addressed” or that a determination has been made as to a facility that “no further action” is warranted at this time.

For the Muni NEI, to record that a facility has an initiated action against it.

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In FYs 11, 12, and 13 we migrated NEI addressing action and universe data from individually maintained Excel spreadsheets into ICIS NSR/PSD Mineral Processing Municipal Infrastructure – CSO and SSO

In the next month or so we plan to migrate the Muni MS4 universe and addressing action data into ICIS, and we are still looking at migrating “Important CAFO” NEI data to ICIS

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The result of this migration effort is that today almost all of the data for the six NEIs is being tracked in ICIS or AFS: All data for the 1) NSR/PSD, 2) Mineral

Processing, 3) Muni CSO/SSO (and soon MS4), and 4) Energy Extraction NEIs is being tracked in ICIS

All data for the 5) Air Toxics NEI is tracked in AFS or ICIS

Most data for the 6) CAFO NEI is tracked in ICIS

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Over the past several years HQ wrote reports for extracting NEI data from ICIS and AFS for managing and reporting on the NEIs: ICIS

FY2011-FY2013 Initiative Inspections report NSR-PSD NEI Investigations report Total # Wet Weather Inspections report Total # CAFO Joint Inspections report Certification NEI Enforcement Case Counts FY2011-FY 2013 report NEI Compliance Determination Report Municipal NEI Spreadsheet Report Mineral Processing NEI Spreadsheet Report NSR-PSD NEI Spreadsheet Report National Enforcement Initiative Environmental Benefits report

AFS Air Toxics Facilities Addressed reports Air Toxics Facilities Evaluated reports

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We also wrote reports specifically for analyzing NEI data quality: ICIS

DQR - Initiated and Concluded National Initiative Cases All report

DQR - National Initiative & Program QA reportMany of the ICIS reports now include one or

more “QA” tabs used to identify possible data quality issues related to the report

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In FY 13 (and very soon for FY14) we put out an NEI Reporting Guide: The NEI Reporting Guide provides detailed

information about what NEI data to report, where to report the data, and detailed instructions on how to enter the data

http://intranet.epa.gov/oeca/oc/resources/etdd/reporting/fy2013/refdocs/reportingfy13-attachment9a5-neiguideparta.pdf

In FYs 13 and 14 we conducted training on NEI data reporting (based on the NEI Reporting Guide)




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So, after all this effort, why do we need to do more?1. Beginning in FY11, via an EPA Website, OECA has been

providing the public with information on our progress and accomplishments in pursuing the six NEIs

http://www2.epa.gov/enforcement/national-enforcement-initiatives

http://www2.epa.gov/enforcement/national-enforcement-initiatives

http://www2.epa.gov/sites/production/files/2013-09/2012-eoy-mineral-inspection.gif

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2. At EOY FY 12, and even more at EOY FY13, we learned that there was significant work to be done to make the NEI data in the data systems reliable.

Particularly at EOY FY13 we began to use the ICIS and AFS NEI reports to examine the quality of the NEI data

These reports proved to be powerful tools for uncovering data issues

Many problems were found with the NEI data, some due to data migration problems, some due to data entry issues

A significant effort was required to make corrections to the NEI data

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3. As a result of the NEI DQ effort at EOY FY13 we wrote a Standard Operating Procedure for NEI data quality review

The SOP fully incorporates NEI DQ as part of the MY and EOY data certification effort

Per the SOP, OC-PMOD and the OC members on the NEI SITs will work with the Regions to review the NEI data at MY and EOY

To reflect the emphasis on NEI data quality, the FY14 data certification form has been changed to state that, “A critical element of the certification process requires that regions have utilized the National Enforcement Initiative (NEI) Data Quality Reports to review the data, make changes in ICIS as necessary, and certify that the NEI data, as corrected in the data system, is accurate and reliable.”

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So . . . to help the Regions and the NEI SIT members to use the ICIS and AFS NEI reports to review the NEI data we thought some training would be useful The DQ review described in this training is based largely

on how we used the ICIS and AFS reports to review the NEI data at EOY FY13

There may well be other ways to use the reports for quality reviewing the NEI data that we have not thought of!

Note that we expect that this effort will diminish and get easier in future FYs as we correct the NEI DQ problems

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What Reports are Particularly Useful for DQ Reviewing Each NEI?

There is significant variability in what reports to use to review the data for each NEI. This is due to the nature of the NEIs

Some NEIs have defined facility universes, others don’t The measures used for each NEI vary across the NEI strategies Air Toxics NEI inspections and addressing actions are tracked

in AFS onlySo, as we discuss the various reports and how to

use them to review NEI data it is important to keep in mind which report is valuable for reviewing which NEI See esp. the chart on slide 17, below

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CAFO NEI ICIS “NEI Compliance Determination Report” ICIS “Total # Wet Weather Inspections” report ICIS “Total # CAFO Joint Inspections” report ICIS “Certification NEI Enforcement Case Counts FY2011-FY 2013”

report ICIS “DQR - Initiated and Concluded National Initiative cases All” report ICIS “DQR - National Initiative & Program QA” report

Municipal Infrastructure NEI ICIS “Municipal NEI Spreadsheet Report” ICIS “Total # Wet Weather Inspections” report ICIS “Certification NEI Enforcement Case Counts FY2011-FY 2013”

report ICIS “DQR - Initiated and Concluded National Initiative cases All” report ICIS “DQR - National Initiative & Program QA” report Note: For reviewing MS4 data at MY it is still necessary to review the

MS4 QuickPlace spreadsheet

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Energy Extraction NEI ICIS “NEI Compliance Determination Report” ICIS “FY2011-FY2013 Initiative Inspections” report ICIS “Certification NEI Enforcement Case Counts FY2011-FY

2013” report ICIS “DQR - Initiated and Concluded National Initiative cases

All” report Mineral Processing NEI

ICIS “Mineral Processing NEI Spreadsheet Report” ICIS “FY2011-FY2013 Initiative Inspections” report ICIS “Certification NEI Enforcement Case Counts FY2011-FY

2013” report ICIS “DQR - Initiated and Concluded National Initiative cases

All” report

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NSR-PSD NEI ICIS “NSR-PSD NEI Spreadsheet Report“ ICIS “NSR-PSD NEI Investigations” report ICIS “Certification NEI Enforcement Case Counts FY2011-FY 2013”

report ICIS “DQR - Initiated and Concluded National Initiative cases All”

report ICIS “DQR - National Initiative & Program QA” report

Air Toxics NEI AFS Air Toxics Addressed/No Further Action Report AFS Air Toxics Evaluations Report ICIS “Certification NEI Enforcement Case Counts FY2011-FY 2013”

report ICIS “DQR - Initiated and Concluded National Initiative cases All”

report

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This chart shows which reports are valuable in reviewing the data for each NEI: Reports marked with a black X are the primary source of data for each NEI. Reports marked with a blue X have data that is useful to compare with the reports that are

the primary source of data for the NEI.

# ICIS/AFS ReportAir

Toxics

NSR/PSD Cement/

Acid/GlassNSR/PSD

CFPP EE

Muni Large

CSO/SSO

Muni Phase 1

MS4Mineral

Processing CAFO

1 FY2011-FY2013 Initiative Inspections Report X X X X X X X X2 Total # Wet Weather Inspections Report X X X3 Total # CAFO Joint Inspections Report X4 Municipal NEI Spreadsheet Report X5 Mineral Processing NEI Spreadsheet Report X6 NSR/PSD NEI Spreadsheet Report X X7 NEI Compliance Determination Report X X X X X X8 Certification Nat'l Enf Initiative Case Counts FY11-FY13 X X X X X X X X9 NSR-PSD NEI Investigations Report X X10 AFS Air Toxics Facilities Addressed report X11 AFS Air Toxics Facilities Evaluated report X12 Manual MS4 NEI QuickPlace Spreadsheets X13 Manual Important CAFO QuickPlace Spreadsheets X

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Reviewing National Enforcement Initiative (NEI) cases for possible

"flagging" issues

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Reviewing National Enforcement Initiative (NEI) cases for possible "flagging" issues

Two ICIS reports are available for helping to identify NEI enforcement case flagging issues in ICIS:1. “DQR - Initiated and Concluded National

Initiative cases All”2. “DQR - National Initiative & Program QA”

These reports are found in the “Federal Enforcement and Compliance Reports / Data Quality Reports” folder

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“DQR - Initiated and Concluded National Initiative cases All” report

The first DQR report: Identifies NEI enforcement cases initiated, with

a judicial complaint filed, or concluded where the “OECA National Priority” field on the ICIS basic information screen or on the ICIS final order screen is not up-to-date

Identifies NEI enforcement case records with one of the “CA Only” priorities selected, as well as cases with multiple NEIs selected

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“DQR - Initiated and Concluded National Initiative cases All” report – “Initiation in FY” tab

This tab shows NEI cases initiated (either Administrative Complaint or Referral to DOJ) in a fiscal year Review this tab for cases listed where the

“Initiation OECA National Priorities” is blank, or appears to be incorrect

When an error is identified, the correct NEI (for the fiscal year in which the case was initiated) should be added/corrected in the “OECA National Priority” field on the ICIS basic information screen

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“DQR - Initiated and Concluded National Initiative cases All” report – “Initiation in FY” tab

Example: the case below has an Administrative Complaint Issued Date in FY 2014 But, the “Initiation OECA National Priorities” selected

in ICIS are FY 2013 priorities These entries should be updated to select FY2014

priorities on the ICIS basic information screen

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“DQR - Initiated and Concluded National Initiative cases All” report – “Jud Comp Filed in FY” tab

This tab shows NEI cases with a Judicial Complaint Filed in a fiscal year Review this tab for cases where the “Initiation

OECA National Priorities” information does not have a value for the fiscal year that the case was filed

The NEI for the fiscal year the judicial complaint was filed should be added to the “OECA National Priority” field on the ICIS basic information screen

The control key must be pressed when adding an entry to this data field, so existing entries to this field are not accidentally removed

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“DQR - Initiated and Concluded National Initiative cases All” report – “Jud Comp Filed in FY” tab

Example: This case has a Judicial Complaint Filed Date in FY 2014 The “Initiation OECA National Priorities” entered in ICIS

is a FY 2012 priority The 2014 priority should be added on the basic

information screen in ICIS Once done, there will be two priorities (2012 & 2014)

entered on the basic information screen

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“DQR - Initiated and Concluded National Initiative cases All” report – “Concluded - NEI blank” tab

This tab shows concluded NEI cases where the “Final Order Year OECA National Priorities” information is blank The NEI for the fiscal year in which the case

concluded should be added to the “OECA National Priority” field on the final order screen in ICIS

Where this correction is required, it is also likely that the “Priority” field on the Complying Action/Inj. Relief screen in ICIS should also be updated (for the appropriate environmental benefit amounts and for the “Cost of Complying Action/Injunctive Relief”)

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Example: Ash Grove Cement enforcement case concluded in FY 2013 The “Final Order Year OECA National Priorities”

information was blank The 2013 priority should be added on the final

order screen in ICIS

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“DQR - Initiated and Concluded National Initiative cases All” report – “CA Only QA list” tab

This tab shows initiated and/or concluded NEI cases where the “Initiation OECA National Priorities” and/or “Final Order Year OECA National Priorities” listed are one of the “CA Only” priorities The "CA Only” (used only for Compliance Assistance

activities) initiative(s) should be changed to the appropriate enforcement action initiative(s) or removed

The “Priority” field on the Complying Action/Inj. Relief screen in ICIS should be checked to assure the correct NEI was selected (for the appropriate environmental benefit amounts and for the “Cost of Complying Action/Injunctive Relief”)

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Example: Cal-Maine Foods ACO concluded in FY 2013 The “Initiation OECA National Priorities” and “Final

Order Year OECA National Priorities” information selected were “CA Only” priorities

These “CA Only” priorities should be replaced with the FY2013 enforcement action priority on the ICIS basic information and final order screens, or removed

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“DQR - National Initiative & Program QA” report

The second DQR report: Identifies initiated and concluded enforcement cases

where the program identified in ICIS is either CAFO, CSO, SSO, MS4, or NSR/PSD, but the "OECA National Priority" field is blank on the ICIS basic information screen and on the ICIS final order screen

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“DQR - National Initiative & Program QA” report –“NEIs Blank” tab

Example: Florida Institute is a CAFO case which concluded in FY 2013 If this is a CAFO NEI case then the appropriate CAFO priority should

be added to the final order screen in ICISExample: Springfield is a SSO case which was initiated

and concluded in FY 2013 If this is a SSO NEI case then the appropriate SSO priority should be

added to the basic information and the final order screens in ICIS

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“Certification National Enforcement Initiative Case

Counts” report

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“Certification National Enforcement Initiative Case Counts” report

This report is valuable for reviewing data for all of the NEIs Muni CSO/SSO, NSR, and Mineral Processing the report is

valuable for comparison with EA data in the 3 Spreadsheet reports For the other 3 NEIs, this report is the primary source of EA data

In this report there is a tab for each of the National Enforcement Initiatives Air Toxics, NSR/PSD, Mineral Processing, CSO, SSO, MS4,

CAFO, and Energy Extraction Within each of these report tabs are crosstabs showing

enforcement case outputs and outcomes by NEI sub-initiative There is also a “NEI All” tab which shows the outputs and

outcomes for all the NEI sub-initiatives This “NEI All” tab is best viewed in Excel

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In the report there are detail lists for each case type, sectioned by region and NEI sub-initiative ACOs, APOCs, Expedited APOCs, Referrals, Civil Judicial

Complaints, FAPOs, Expedited FAPOs, Civil Judicial Conclusions

There are also detail lists showing: all administrative concluded cases, and all judicial concluded cases

There is also a tab which shows enforcement cases with multiple National Enforcement Initiatives selected

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The cases listed in the “Certification National Enforcement Initiative Case Counts” report should also be listed in the corresponding NEI Spreadsheet report (for the Muni CSO/SSO, NSR/PSD and Mineral Processing NEIs) If a case is listed in the Case Counts report, but not in the NEI

Spreadsheet report, then: the case is linked to a facility that is either not flagged as being in the

NEI universe or is incorrectly flagged or the case is improperly flagged as being part of a NEI

Note: If a case is correctly flagged and linked to the correct NEI flagged facility, but still is not showing up on the “By Facility” tab of the spreadsheet report then it is not the most recent NEI flagged enforcement case involving this facility. The case should appear, however, in the “By Activity” tab.

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“Certification National Enforcement Initiative Case Counts” report - Example

The case shown below is listed in the “Details – Admin” tab of the NEI Case Counts report

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“Certification National Enforcement Initiative Case Counts” report – Example, continued

The case is also listed for the Starkville POTW (FRS ID: 110002307343) in the Municipal NEI Spreadsheet report

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“Certification National Enforcement Initiative Case Counts” report – Example, continued

The case is correctly linked to the facility (Programmatic ID: NPDES MS0036145; FRS ID: 110002307343) that is properly flagged as part of the “SSOs >= 10 mg/d and < 100 mg/d” universe

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“Total # Wet Weather Inspections” report

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In this report are the following tabs: Crosstab CSO SSO CAFO Details CSO SSO CAFO Crosstab Stormwater Details Stormwater

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The inspections listed in the “Total # Wet Weather Inspections” report generally should also be listed in the Municipal NEI Spreadsheet report If an inspection is listed in the Wet Weather Inspections

report, but not in the Municipal NEI Spreadsheet report, then: the inspection is linked to a facility that is either not flagged as

being in the NEI universe or is incorrectly flagged or the inspection is improperly flagged as being part of a NEI

Note: If an inspection is correctly flagged and linked to the correct NEI flagged facility, but still is not showing up on the “By Facility” tab of the spreadsheet report then it is not the most recent NEI flagged inspection involving this facility. The inspection should appear, however, in the “By Activity” tab.

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“Total # Wet Weather Inspections” report – Example # 1

The inspection shown below is listed in the “Details CSO SSO CAFO” tab of the Wet Weather Inspections report

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“Total # Wet Weather Inspections” report –Example # 1, continued

The inspection is also listed for the East Shore Wastewater Treatment Plant (FRS ID: 110001730770) in the Municipal NEI Spreadsheet report

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“Total # Wet Weather Inspections” report – Example # 2

The inspection shown below is also listed in the “Details CSO SSO CAFO” tab of the Wet Weather Inspections report But, this inspection is not listed in the Municipal NEI

Spreadsheet report

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“Total # Wet Weather Inspections” report –Example # 2, continued

The inspection is linked to the facility (Programmatic ID: NPDES ME0100013; FRS ID: 110000916251) that is NOT flagged as part of the “SSOs >= 10 mg/d and < 100 mg/d” universe Either the universe flag needs to be added for this facility

(unlikely, and requires SIT input), or the “SSOs >= 10 mg/d and < 100 mg/d” NEI flag should be removed from the inspection

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“NSR-PSD NEI Investigations Report”

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The inspections listed in the “NSR-PSD NEI Investigations Report” generally should also be listed in the NSR-PSD NEI Spreadsheet report If an inspection is listed in the NSR-PSD NEI Investigations

report, but not in the NSR-PSD NEI Spreadsheet report, then: the inspection is linked to a facility that is either not flagged as

being in the NEI universe or is incorrectly flagged or the inspection is improperly flagged as being part of a NEI

Note: If an inspection is correctly flagged and linked to the correct NEI flagged facility, but still is not showing up on the “By Facility” tab of the spreadsheet report then it is not the most recent NEI flagged inspection involving this facility. The inspection should appear, however, in the “By Activity” tab.

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In this report are the following tabs: Crosstab by sub-initiative and actual start fiscal year Crosstab by sub-initiative and Region Details Details QA 1 Details QA 2 Details QA 3 Details QA 4

Shows all ICIS inspections, information requests, and investigations. All are counted for ACS commitments, but only “initiated investigations” are tracked for website.

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“NSR-PSD NEI Investigations Report” – Details QA 1

Shows investigation activities at a facility that is part of the universe, but was not flagged with a National Priority indicator (or was flagged with an incorrect indicator, e.g. flares).

Resolution in ICIS Nothing if the activity was not part of the NEI Add or correct National Priority Indicator on Compliance

Monitoring screen if appropriate

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Shows investigation activities at a facility that is not part of the universe, but was flagged with a National Priority indicator.

These will not show up in Spreadsheet report.Resolution in ICIS

Remove the National Priority Indicator if the facility in not part of the NEI Universe

Check the NSR-PSD Spreadsheet report to see if the wrong facility id may have been selected. Due to data quality issues within FRS, some facilities might be linked to multiple FRS IDs. If this error is discovered, work with the regional data quality steward to correct the problem.

Add the universe indicator to the facility. This should only be done as a last resort, and only with SIT approval.

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Shows inspection activities (not investigations) that are linked to a facility that is part of the NSR-PSD NEI universe or has an NSR-PSD initiative selected, and has a non-NULL priority type.

If the activity is linked to an NSR-PSD priority type, it will be counted for ACS purposes.

This can also be used to verify if the inspection activity was flagged for the incorrect NEI.

If the facility does not have an NSR-PSD universe indicator, it will not be listed in the Spreadsheet report.

These will not be counted as facilities with initiated investigations for NEI website purposes. Per the NEI Reporting Guide, activities should be added as investigations if they are initiated investigations under the NEI.

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Shows inspection activities (not investigations) that have no NEI priority indicator at a facility that is part of an NSR-PSD universe.

These activities will not be counted for ACS as part of the NEI and will show up in the NSR-PSD Spreadsheet report in the QA Report # 1 tab.

These will not be counted as facilities with initiated investigations for NEI website purposes. Per the NEI Reporting Guide, activities should be added as investigations if they are initiated investigations under the NEI.

This can also be used to verify if the inspection activity should have been flagged for an NSR-PSD NEI.

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“FY2011-2013 Initiative Inspections Report”

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“FY2011-2013 Initiative Inspections Report”

Listed as being for FY2011-2013, but just as applicable for FY2014-FY2016

This report is valuable for reviewing data for all of the NEIs Primary source of data for EE and Mineral Processing

Initiatives May be used to compare to NEI specific inspection

reports for Air Toxics, CAFO, and NSR/PSD Also valuable for comparing to the 3 Spreadsheet reports

In this report there is a Counts crosstab, a detail tab for All NEIs, detail tabs for each of the National Enforcement Initiatives separately, and a “CA Only” tab

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“FY2011-2013 Initiative Inspections Report” – Counts tab

Two sets of counts, one by statute, and one by law code. Totals do not match because some inspections have

multiple law codes. Count by statute is certified total.

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“FY2011-2013 Initiative Inspections Report” – Counts tab

Review for statutes and law codes that may not be applicable for the NEI (e.g., RCRA for Energy Extraction)

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“FY2011-2013 Initiative Inspections Report” – Details tab

Review for statutes and law codes that do not apply to NEI (e.g., RCRA for Energy Extraction)

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“FY2011-2013 Initiative Inspections Report” – Details tab

Note: Total records in details tab do not match statute totals in “Counts” crosstab because the details show all law codes listed for the inspection

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“FY2011-2013 Initiative Inspections Report” – CA Only

This tab shows initiated and/or concluded NEI inspections where the national priorities code is one of the “CA Only” priorities The "CA Only” (used only for Compliance

Assistance activities) initiative(s) should be changed to the appropriate initiative(s) or removed

The “Priority” field on the Complying Monitoring screen in ICIS should be checked to assure the correct NEI was selected

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Reviewing Compliance Determinations/Addressing

Actions

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Reviewing Compliance Determinations/Addressing Actions

Two types of reports are available in ICIS:1. “NEI Compliance Determination” – Used

primarily for non-universe NEIs (EE and CAFO)2. “[XXX] Spreadsheet Report” – One for each

universe NEI (Municipal, NSR-PSD, and Mineral Processing)

These reports are found in the “Federal Enforcement and Compliance Reports / National Standard Reports” folder

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“NEI Compliance Determination” report

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“NEI Compliance Determination” report

This report is/will be valuable for reviewing data for all of the NEIs Primary source of data for EE and CAFO Initiatives Valuable for comparing to the 3 Spreadsheet reports

to see if NEI determinations are flagged for facilities that are not part of the NEI universe

Will be useful for MS4 and Air Toxics activities once they are migrated into ICIS

In this report there are Crosstabs for Addressing Actions and No Further Action Determinations, Details by Facility, and Details By Activity

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“NEI Compliance Determination” report – Crosstabs

Crosstabs shows Addressing Actions and No Further Action Determination by Region for each NEI and sub initiative. Verify totals match what region expects for each determination type. When comparing to Spreadsheet Reports, verify crosstab totals match. If

totals don’t match, a facility that is not part of the universe may have a determination associated with it.

Addressing Action No Further Action

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“NEI Compliance Determination” report – Details By Facility

Summarizes determinations with one line per facility Only data on most recent determination appears, but the count

column identifies if additional data exists. Generally, there should only be one determination per facility.

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“NEI Compliance Determination” report – Details By Activity – Example #1

Shows all activities associated with each facility. Not as easy to use for initial review in Excel, but good for QA. Use “Find” Function to search for FRS ID

This example shows two determinations linked to the same Program ID. One of these determinations should probably be removed. Pay attention to the definitions of Addressing Action Determinations in the

strategies and reporting guide. Determinations might mistakenly be added twice because of confusion over which date qualifies as the addressing action (Referral v. Conclusion)

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“NEI Compliance Determination” report – Details By Activity – Example #2

This example shows determinations at multiple program IDs for the same facility. This may be an FRS data linkage issue that needs to be

corrected with the Regional FRS Data Steward. For EE, this could be determinations at different wells at

the same site.

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“NEI Compliance Determination” report – Reviewing Data in ICIS

When searching for Determination activities in ICIS, use the facility search function instead of the Compliance Determination Search The compliance determination search date filters based on

the “Compliance Determination Date”, not the NEI Addressing Action or No Further Action Dates. You probably won’t be able to find the activity you are searching for since it’s not a required field.

Instead use the Facility Search using the FRS ID or Program ID, then click on the “Compliance Determinations” tab.

Make sure you are looking at the correct Program ID record for the facility, or you might not find the determination you’re looking for.

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“[XXX] Spreadsheet Report”

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“[XXX] Spreadsheet Report”

Spreadsheet Reports exist for NEIs in ICIS with a defined universe (Municipal, NSR-PSD, and Mineral Processing), and are intended to replace the Excel spreadsheets previously maintained by the SITs

The Spreadsheet Reports are essentially the same, but have slight differences based on how determinations and “initiated but not concluded” are defined for each NEI

Spreadsheet Reports only show data on facilities in the NEI Universe, but show data for determinations, enforcement actions, and inspections.

Note: for the Municipal NEI, do not run it for both CSO and SSO at the same time. Also, the SSO universe exceeds the query limit in ICIS and cannot be run nationally; it has to be broken up into Region 1-5 and 6-10

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“[XXX] Spreadsheet Report”– By Facility

Summarizes data with one line per facility. Shows most recent determination, enforcement

action, and inspection/investigation information.

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“[XXX] Spreadsheet Report”– By Facility – Example #1

Determination data does not match enforcement action data or inspection/investigation data Enforcement action was not flagged with corresponding

Priority (Check QA Report #1 Tab to see if an action exists) Need to update determination with addressing action date Need to add determination

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“[XXX] Spreadsheet Report”– By Facility – Example #2

Facilities should only have one compliance determination. As in Determination Report, check By Activity tab to review details. Could be separate entries for initiation and conclusion. Could be duplicate entries based on multiple Program IDs for same

facility. Could be duplicate entries based on definition confusion (referred v.

concluded) Could be updated entries if addressing action follows a no further action

determination (Federal Enforcement after State Enforcement) Could be FRS data linkage issue.

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“[XXX] Spreadsheet Report”– By Activity

Shows all activities associated with each facility that have been flagged with corresponding Priority Flag. Not as easy to use for initial review in Excel, but good for QA. Use “Find” Function to search for FRS ID .

If expected activity does not appear on this tab, check QA Tab #1

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“[XXX] Spreadsheet Report”– QA Report #1

Shows all activities associated with each facility that do not have a priority flag that matches the universe indicator. Use “Find” Function to search for FRS ID .

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“[XXX] Spreadsheet Report”– Crosstab by Date

Shows size of universe and Addressing Action Status by Year. If there are facilities with multiple determinations, the by Date totals

may not match the by Region totals due to double counting. If a determination has an addressed date and a no further action date, it

is only counted in the addressed tab.

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“[XXX] Spreadsheet Report”– Crosstab by Region

Shows size of universe and Addressing Action Status by Region. If there are facilities with multiple determinations, the by Date totals may

not match the by Region totals due to double counting. If a determination has an addressed date and a no further action date, it is

only counted in the addressed tab.

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“[XXX] Spreadsheet Report”– Initiated not Concluded

Two crosstabs (one by date and one by region)Municipal shows Determinations Initiated not Concluded,

NSR-PSD and Mineral Processing will have Enforcement Action Initiated not Concluded Crosstabs added.

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“[XXX] Spreadsheet Report”– Facilities Inspected by Date

Crosstab of inspection dates by Fiscal Year Useful for ACS purposes. May not be accurate for inspections too far in the past. Counts inspections in each Fiscal Year, and thus cannot be used alone

to determine the number of facilities inspected in the universe.

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“[XXX] Spreadsheet Report”– Facilities Inspected by Date QA

Shows when a facility was inspected in multiple years.

Used to manually adjust inspection date counts to get the inspection status by year.

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“[XXX] Spreadsheet Report”– Facilities Inspected by Region

Crosstab of inspection dates by Region Does not double count inspections in multiple fiscal years. May not be accurate due to inspections too far in the past

without initiative flag.

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Reviewing Activities for Air Toxics NEI in AFS (Prior to ICIS-AFS Migration)

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Reviewing Activities for Air Toxics NEI in AFS

Two manually run reports provided to SIT and posted to the Data Depot for regions to review: AFS Air Toxics Addressed/No Further Action Report AFS Air Toxics Evaluations Report

Currently used for ACS and website counts QA Tabs if facility and activity flags do not match Evaluations include those flagged with NEI, and all MACT

evaluations regardless of whether they are flaggedOECA is currently reviewing how to import Air

Toxics NEI data during AFS-ICIS migration

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The End

to access the webinar: https://epa.connectsolutions.com/neidqreview/ and dial: conference call #:...

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