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 Process
1. OECA Suite of Measures Summary (OSMS Dashboard) Version 2.0
2. Accessing OECA Suite of Measures Summary
3. Certification Process Change: Reduced ICIS Preliminary Data Pull
4. Certifying the Data
Environmental Justice
5. ICIS Environmental Justice Reporting: Transition to EJSCREEN and Changes to ICIS Data
Fields
National Enforcement Initiative (NEI) Reporting
6. Summary of FY 2013 NEI Reporting
7. 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 Amounts
10. Avoid Double Counting of Environmental Benefits
11. Reporting Outcomes from CWA, CSO, and SSO Enforcement Actions
Reminders
12. Reminder: Continue to Enter Big Case Projection Data
13. Reminder: Supplemental Environmental Project (SEP) Reporting
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Attachments
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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
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DATA QUALITY REVIEWS AND CERTIFICATION PROCESS
1. OECA Suite of Measures Summary (OSMS Dashboard) Version 2.0
The 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
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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.
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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
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“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
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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 endof-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 Reporting
National 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.
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ICIS will become the official database for tracking the CSO and SSO sub-initiatives starting at midyear. 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 Information
The 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
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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 Act
o 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: NPDESStormwater-MS4
o Complying Action Category Type: <select> Reduction of Ongoing Releases
o Complying Action Type: <select> Green Infrastructure Cost Estimate
o Units: <select> Dollars
o Amount: <enter> Estimated cost for required green infrastructure remedies
o Media: Water (navigable/surface)
-ORo Complying Action Category Type: <select> Reduction of Ongoing Releases
o Complying Action Type: <select> Green Infrastructure Enabling Language
o Units: <select> Dollars
o 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.
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If you have questions regarding the reporting instructions below, please contact Donna Inman, at
202-564-2511, inman.donna@epa.gov. For questions regarding the National Municipal
Infrastructure Compliance and Enforcement Strategy, you may contact Amy Porter, at 202-5642431, porter.amy@epa.gov, or Seth Heminway, at 202-564-7017, heminway.seth@epa.gov.
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 [klaus.dan@epa.gov or
(202) 564-7757].
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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 Amounts
During 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)
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.
1
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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
Hazardous waste material that
meets the regulatory definition
of “hazardous waste” and is
not mixed with an
environmental medium.
Hazardous or toxic
materials/substances that:
a) contain hazardous or toxic
constituents,
b) do not meet the regulatory
definition of “hazardous
waste” and,
c) are not mixed with an
environmental medium.
Performance Measure in
which Benefits are Counted
“Hazardous Waste Treated,
Minimized or Properly
Disposed of”
Applicable
Unit
Impacted
Medium
Pounds
Land or Soil
Depending on the medium impacted “Estimated Toxics and
Pesticides Reduced, Treated
or Eliminated”
“Estimated Air Pollutants
Reduced, Treated or
Eliminated”
“Estimated Water Pollutants
Reduced, Treated or
Eliminated”
Pounds
Land
Pounds
Air
Pounds
Water
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Type of Material Addressed,
Remediated, Cleaned up
“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.
Performance Measure in
which Benefits are Counted
Applicable
Unit
Impacted
Medium
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 202-5642511, or via email at: inman.donna@epa.gov.
10. Avoid Double Counting of Environmental Benefits
As 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 202-5642511, or via email at: inman.donna@epa.gov
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11. Reporting Outcomes from CWA, CSO, and SSO Enforcement Actions
For 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 Data
Regional 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.
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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.
15
Early Notice of New and Changed Reporting Requirements
for FY 2013 Enforcement and Compliance Data