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Detailed Facility Report: Data Dictionary

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 Summary

This document provides users with a list of the variables and definitions that have been incorporated into the Detailed Facility Report. The Detailed Facility Report provides a concise enforcement and compliance history for the facilities selected in your query using EPA's Integrated Data for Enforcement Analysis (IDEA) system. Each facility is tracked for compliance under three environmental statutes: the Clean Air Act (CAA), the Clean Water Act (CWA), and the Resource Conservation and Recovery Act (RCRA). Inspection, enforcement, and compliance data are compiled from the three program office data systems associated with these laws:

  • Air Facility System (AFS);
  • Permit Compliance System (PCS) and Integrated Compliance Information System (ICIS); and
  • RCRA Information System (RCRAInfo).

Click here for more information on numbers and types of facilities tracked in EPA's data systems.

Federal enforcement actions are also tracked in the Integrated Compliance Information System (ICIS). In addition to the National Pollutant Discharge Elimination System (NPDES) data for some states, ICIS contains information on federal administrative and federal judicial cases under the following environmental statutes: the Clean Air Act (CAA), the Clean Water Act (CWA), the Resource Conservation and Recovery Act (RCRA), the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313, the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund), the Safe Drinking Water Act (SDWA), and the Marine Protection, Research, and Sanctuaries Act (MPRSA). ICIS may contain duplicates of actions and penalties shown in the program databases.

Please note that the Detailed Facility Report is an aggregate report; that is, it summarizes data from the source databases and presents them in a meaningful and succinct manner. Different tracking methods and indicators across the source databases necessitate that some data within the Detailed Facility Report be displayed differently.

Note that the date the report is generated appears at the top of the report. The date that the individual databases were last uploaded to IDEA appears at the bottom of the report. Data entered into the systems after the 'refresh' dates shown at the bottom of the report are not available. Data in IDEA are refreshed once per month, usually in the middle of each month. While EPA has extensive data quality processes in place, users may find it necessary to contact the state or local agency if data are missing. In some cases, state/local governments will have additional information (see more on state data).

The Detailed Facility Report is organized into the following sections for each facility matching your query:

  1. Facility Permits and Identifiers
  2. Facility Characteristics
  3. Inspection and Enforcement Summary Data
  4. Compliance Monitoring History
  5. Compliance Summary Data
  6. Three Year Compliance Status by Quarter
  7. Notices of Violation or Informal Enforcement Actions
  8. Formal Enforcement Actions
  9. Formal Enforcement Actions - ICIS
  10. Environmental Conditions
  11. Demographic Profile of Surrounding Area

Compliance and enforcement data are separate from information not related to compliance (i.e., demographic data). The Detailed Facility Report contains a demographic section which uses U.S. Census data and draws from the Census Block Group Data (CBG) database. The CBG database is derived from the 2000 Census of Population and Housing Summary Tape Files 1A and 3A. Statistics are shown for the area within a 3-mile radius of each facility. More detailed information is available by clicking the 1 mi, 3 mi or 5 mi links (links leave ECHO). The total population within a given radius of a facility is one indicator of the facility's surrounding environment and provides context for other facility indicators. This indicator does not imply that there is any exposure to the identified population.

Not all report sections will necessarily be present for each facility. If a report section is absent for a given facility, it simply means there were no relevant data matching the content of that section.

For the purpose of this report, the "last three years" is defined as the twelve most recently completed quarters, plus data from the current quarter up until the refresh date. The last five years will include data from the twenty most recently completed quarters, plus data from the current quarter up until the refresh date. A "quarter" is any of the following 3-month periods: January-March, April-June, July-September, or October-December.


 Facility Permits and Identifiers

The Facility Permits and Identifiers section of the Detailed Facility Report provides the associated statute, system, source ID, facility name, and address for program records that are associated with a particular Facility Registry System (FRS) ID. FRS links all program database records (such as permit IDs and IDs facilities use in reporting to EPA) together. FRS Identifiers appear on the first line of the Detailed Facility Report.

Facilities may be regulated under more than one environmental statute depending on the size and nature of the operations of the facility. Definitions for the column headings are given below:

Statute

The name of the statute associated with each of the permits and identifiers linked to the facility:

  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery Act; and
  • EP313 = the Emergency Planning and Community Right-to-Know Act, Section 313 (also known as the Toxics Release Inventory Program).
System

The EPA data system in which permit and facility records are kept. EPA's Facility Registry System (FRS) links all program database records (such as permit IDs and IDs facilities use in reporting to EPA) together. The following list describes the individual data systems that are linked to from the detailed facility report:

  • AFS - Air Facility System for Clean Air Act stationary source programs;
  • ICP - Integrated Compliance Information System for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits;
  • PCS - Permit Compliance System for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits;
  • RCR - Resource Conservation and Recovery Act Information System (RCRAInfo) for tracking the Resource Conservation and Recovery Act (RCRA) programs;
  • NCDB - National Compliance Database System for monitoring national performance of the Toxic Substance Control Act (TSCA); the Emergency Planning and Right-to-Know Act, Section 313 (EPCRA); the Asbestos Hazard Emergency Response (AHERA); and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and
  • TRI - Toxics Release Inventory for Emergency Planning and Community Right-to-Know Act, Section 313 submissions.
Source ID An alphanumeric field, which is a unique value for each record/permit/site within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility. PCS and TRI identifiers in this section are linked to more data from their respective data systems. The Permit Compliance System (PCS) link allows users to view more details concerning NPDES permit limits and effluent monitoring. The Toxics Release Inventory (TRI) link allows users to view more details concerning self-reported information on annual chemical releases and transfers. These two links leave the ECHO Web site. The links connect to the Envirofacts Data Warehouse, operated by the EPA Office of Environmental Information.
Facility Name Company or permit holder name, as maintained by each data system. The facility name may differ across EPA databases due to differences in reported information, change in ownership, use of parent or subsidiary name, etc.
Street Address Street address where facility is located, as maintained by each data system. Certain data systems also maintain mailing address information, which is not used in this report. The street address may differ across EPA databases due to differences in reported information (e.g., use of mailing address), change in ownership, use of parent or subsidiary address, etc.
City City where facility is located, as maintained by each data system. The city may differ across EPA databases due to differences in reported information, use of parent or subsidiary location as mailing address, etc.
State State, as maintained by each data system. The state may differ across EPA databases due to differences in reported information, use of parent or subsidiary location as mailing address, etc.
Zip US postal Zip code, as maintained by each data system. The zip code may differ across EPA databases due to differences in reported information, use of parent or subsidiary location as mailing address, etc.

 Facility Characteristics
This table of the report provides more specific information on the facility. As with the Permit and Identifiers table, this information is taken from each of the program specific databases. Definition for column headings are shown below:
Statute

The name of the statute associated with each of the permits and identifiers linked to the facility: Only CAA, CWA, RCRA, and EP313 are displayed in this section. The first line of this section is normally the Facility Registry System (FRS) data so the statute box is blank.

  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery Act; and
  • EP313 = the Emergency Planning and Community Right-to-Know Act, Section 313.
Source ID An alphanumeric field, which is a unique value for each record/permit/site within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.
Facility Universe

This field provides further description on type of permit or record for each data system as follows:

For CAA - The program office defines each CAA Source ID and the associated permits as being Federally Reportable or Non-Federally Reportable. Under the CAA, federally reportable permits include majors, synthetic minors, NESHAP minors, and other minors in High Priority Violation (HPV) or with recent enforcement actions. The Clean Air Act requires that all federally reportable sources be tracked in a data system, which is the Air Facility System (AFS).

For CWA - Each CWA Source ID or National Pollutant Discharge Elimination System (NPDES) permit is defined by the program office as a Major or Minor discharger. Unlike major permits, most minor permits do not have federal monitoring requirements. For ICIS-NPDES data, this field also indicates the permit type.

For RCRA - RCRA Source ID or permits for Treatment, Storage and Disposal facilities are identified by TSD, Large Quantity Generators are identified by LQG. Other values include Permit Workload (PMT), Closure Workload (CLO), Small Quantity Generator Universe (SQG), Conditionally-Exempt Small Quantity Generator (CESQG), Post-Closure Workload (POST CL), and Transporters.

Click here for more information the types of facilities tracked in EPA's data systems.

Facility Status

The Air Program Status is given for each source ID:

  • Operating;
  • Planned;
  • Under construction;
  • Temporarily closed;
  • Permanently closed; and
  • Seasonal

For CWA, the Permit Compliance System (PCS) designates a permitted facility as being Active or Inactive. Under the CWA, all facilities discharging pollutants from a point source (e.g., a pipe) to surface waters must have a NPDES permit. For CWA, ICIS-NPDES designates a permit as Effective, Administratively Continued, Expired, Not Needed, Pending, Retired, or Terminated.

RCRA facilities ("sites") are designated as Active or Inactive. The following provides RCRA site activity status definitions and explains site activity status designation.

  • Active Site designation
    is an indication based on the information currently in the Agency's RCRAInfo database, that there may be an activity on a site that could be subject to the Resource Conservation and Recovery Act, Subtitle C, or to a state's authorized hazardous waste program. This designation has no legal significance and does not constitute a legally enforceable or binding determination about the status of a particular site or the obligations of an owner or operator.


  • Inactive Site designation
    is an indication based on the information currently in the Agency's RCRAInfo database, that there may not be an activity on a site that could be subject to the Resource Conservation and Recovery Act, Subtitle C, or to a state's authorized hazardous waste program. This designation has no legal significance and does not constitute a legally enforceable or binding determination about the status of a particular site or the obligations of an owner or operator.

The overall activity status of a site is Active if the site has activities from any of the five subcategories below. If a site does not have any activity in any of the five subcategories, then the site is deemed Inactive. Only activities that are known to EPA or a state with an authorized hazardous waste program that have been entered into the national program database, RCRAInfo, will be considered in determining a site's activity status. (Note: Active means a site has activities occurring that are regulated under the federal Resource Conservation and Recovery Act (RCRA), Subtitle C, or an authorized state's hazardous waste management regulations/statutes; or a site which has not been determined to be inactive for such regulated activities. Activity status is determined from the information most recently submitted by a site's representative or determined by EPA or state authority. Federal regulations do not require a subsequent notification if a non-treatment, storage, or disposal facility (TSDF) changes its status (requirements vary from state to state); however, TSDFs are required to notify when owner/operator information changes. Therefore, non-TSDF data may show a site activity status that is no longer current at the site. Activity status definitions are intended only for the purposes of data management and providing the public with information about hazardous waste or other RCRA Subtitle C activities. The designation of a site as "active" or "inactive" and the subcategories below have no legal or regulatory significance.)

  1. Site Identification (SI) Activities are the regulated activities (except TSD and "Other" Universal Waste ("Other" Universal Waste is considered a state-specific activity discussed in subcategory 5)) reported in Section 10 on the federal RCRA Subtitle C Site Identification (SI) Form (or 8700-12) or state-equivalent form. Only current activities (as determined by the RCRAInfo universe calculations) are considered. If any of these activities are checked as present at a site, then the site is considered to have SI activities.


  2. TSD Activities are treatment, storage, disposal (TSD) activities for which EPA may enforce federal RCRA TSDF regulations, permits, and orders or a state may enforce regulations, permits, and orders under its authorized hazardous waste management plan. A site is considered to have TSD activities if one or more of its TSD units have a current Legal/Operating status code combination indicating it is in the Regulated ("R") Universe. (This definition may be revised.)


  3. Converters conduct no specific activity and are a special case. They are former TSD units that a site "converted" to hazardous waste activities not requiring a permit, but have not been closed by the site as required by EPA or a state. A site is considered to have Converter status if one or more of its units have a current Legal/Operating status code combination indicating it is in the Converter ("V") Universe. (This definition may be revised.)


  4. CA Activities are those Corrective Action (CA) activities for which a site is subject to enforceable RCRA obligations. The presence of the site in the RCRAInfo Corrective Action Workload Universe is the method by which a site is determined to be active. (This definition may be revised.)


  5. State-specific Activities are activities, other than those listed under the previous four subcategories, which a state regulates and tracks in RCRAInfo and whose presence at a site the state considers sufficient reason to determine the site to be "active." These additional activities may be "same as," "more stringent than," or "broader in scope" than federal regulations. They are generally state variants of SI or TSD activities.

When a site is shown as Active on the Detailed Facility Report, one to five characters in parentheses will indicate the activities that led to the Active designation. The following list provides a definition for each character that may be displayed:

H -   Handler activities (activities found on the federal SI form or a state-equivalent form) (Corresponds to subcategory 1 above.)
P -   Permitting activities (site has at least one unit that is "active" according to RCRAInfo Legal/Operating Status) (Corresponds to subcategory 2 above.)
A -   Corrective Action activities (site is in the RCRAInfo Corrective Action Workload Universe) (Corresponds to subcategory 4 above.)
C -   Converter (the site has at least one unit that is a converter according to RCRAInfo Legal/Operating Status) (Corresponds to subcategory 3 above.)
S -   State-specific activities (site has state-defined activities in the RCRAInfo Permitting or Handler module which the state wants included in the activity status calculation) (Corresponds to subcategory 5 above.)

Areas Displays Clean Air Act stationary source program subpart designation, Clean Water Act-NPDES permit component(s), and/or other Resource Conservation and Recovery Act designations, if any.
Permit Expiration Date (CWA only)

Date on which a given permit is scheduled to expire. An expired date does not mean the facility is operating without a permit. In most cases, the facility has applied for a permit renewal, but the responsible authority (local, state, or federal) has not completed the re-issuance. Typically facilities operate under the conditions of the expired permit until the renewal has been processed. Some states are experiencing a backlog in issuing permit renewals, particularly under the Clean Water Act. EPA suggests contacting the relevant state agency for more information about permit renewal status.

Lat/Long The latitude and longitude of the facility or permit holder as maintained in each data system.
Indian Country A value of "N/A" (Not Applicable) indicates this information is not maintained in the program data system. "No" indicates the facility is not in Indian Country, and a value of "Yes" indicates the facility is in Indian Country according to the source database.
Primary and Secondary SIC Codes Standard Industrial Classification (SIC) codes, as maintained by each data system. SIC codes were established by the Census Bureau to identify processes, products and services. Each data system has different criteria for incorporating this information (e.g., for Toxics Release Inventory reporting, the SIC codes are self-reported by the facility each year).
NAICS Codes The North American Industry Classification System (NAICS) has replaced the U.S. Standard Industrial Classification (SIC) system. For detailed information about NAICS and for a crosswalk between NAICS and SIC codes, please check the U.S. Census Bureau NAICS exit EPA disclaimer page. 
Performance Track Facility Performance Track is a public/private partnership recognizing top environmental performance among participating U.S. facilities of all types, sizes, and complexity, public and private. Program partners are providing leadership in many areas, including preventing pollution at its source. Click here for more information about the Performance Track Program. 

 Inspection and Enforcement Summary Data
Statute

The name of the environmental statute associated with each of the permits and identifiers linked to the facility. Only CAA, CWA, and RCRA are displayed in this section.

  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery Act
Source ID

An alphanumeric field, which is a unique value for each record/permit/site within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.

Insp Last 5 Yrs The number of inspections/compliance evaluations that have occurred at the facility, under the corresponding statute, within the last five years. The last five years will include data from the twenty most recently completed quarters, plus data from the current quarter up until the refresh date. This count only includes inspection types that are counted as inspections in official counts. See the "Inspection History" section for a list of inspection types counted.
Date of Last Insp The date on which the most recent inspection of the facility took place. For the Clean Air Act, the date on which a Full Compliance Evaluation (FCE) was completed. This date may or may not correspond to an actual site visit. A series of partial on- or off-site inspections may have been conducted during the fiscal year as part of this FCE.
Formal Enf Act Last 5 Yrs The number of formal enforcement actions that have been taken against the facility, under the corresponding statute, within the last five years. This count only includes enforcement actions that have been entered in the program databases: AFS, PCS, ICIS-NPDES, and RCRAInfo. Federal CAA, CWA-PCS, and RCRA enforcement actions that have been entered into ICIS are not included in this section to avoid duplicative counting. (Please note that all actions at NPDES facilities in states using ICIS-NPDES are counted.) Please refer to the Formal Enforcement Actions section to determine which actions qualify.
Penalties Last 5 Yrs The total dollar amount of either assessed (or final) penalties. This count only includes penalties that have been entered in the program databases: AFS, PCS, ICIS-NPDES, and RCRAInfo. Federal CAA, CWA-PCS, and RCRA penalties that have been entered into ICIS are not included in this section to avoid duplicative counting. This count does not include proposed penalties in RCRAInfo or the cost of Supplemental Environmental Projects (SEPs).

 Compliance Monitoring History
The Compliance Monitoring History section of the Detailed Facility Report lists inspections/compliance evaluations that have occurred under the Clean Air Act (CAA); the Clean Water Act (CWA); the Resource Conservation and Recovery Act (RCRA); the Toxic Substances Control Act (TSCA); the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Emergency Planning and Community Right-to-Know Acts (EPCRA) over the past five years. Inspections include all federal and state inspections that are reported into federal data systems using federally-designed codes. Italicized entries include various compliance monitoring activities that do not qualify as inspections under EPA's official Office of Enforcement and Compliance Assurance performance measures. Definitions for column headings are given below:
Statute

Designation of the statute associated with each of the permits and identifiers linked to the facility.

  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery Act;
  • TSCA = Toxic Substances Control Act;
  • FIFRA = Federal Insecticide, Fungicide, and Rodenticide Act;
  • EP313 = Emergency Planning and Community Right-to Know-Act (EPCRA) Section 313.
Source ID An alphanumeric field, which is a unique value for each record/permit/site within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.
Inspection Type

A description of the type of inspection undertaken. The Detailed Facility Report includes inspections which were conducted within the last five years. The last five years will include data from the twenty most recently completed quarters, plus data from the current quarter up until the refresh date. Italicized inspection types are not part of EPA official counts. The following inspection types are included in official counts:

Clean Air Act (CAA)

EPA and states used one set of inspection codes prior to October 1, 2001 for "official inspections" under the CAA. These include the codes listed below. Beginning on October 1, 2001, a policy and subsequent database change created a set of new codes that are used to designate "compliance evaluations." A Full Compliance Evaluation (FCE) includes comprehensive paperwork review and often, but not necessarily, an on-site inspection. Codes that continue to be "credited" as official inspections include FS, FF, FE and FZ (shown in bold).

  • 1A - EPA Inspection, Level 2 or greater
  • 2A - EPA Source Test Conducted
  • 3A - Owner/Operator-Conducted Source Test
  • 5C - State Inspection, Level 2 or greater
  • 6C - State Source Test Conducted
  • FS - State Conducted FCE/On-Site
  • FF - State Conducted FCE/Off-Site
  • FE - EPA Conducted FCE/On-Site
  • FZ - EPA Conducted FCE/Off-Site
  • TO - EPQ Required (0/0 COND) Stack Test/observed & reviewed

Under the current system, compliance evaluations which do not qualify as FCEs are characterized as "partial." Partial means that some compliance monitoring was done, but all requirements were not met to receive credit for a Full Compliance Evaluation. The following codes are not included in official counts and indicate partial compliance evaluations:

  • 1A - EPA Inspection, Level 2 or greater
  • 2A - EPA Source Test Conducted
  • 5C - State Inspection, Level 2 or greater
  • 6C - State Source Test Conducted
  • EC - EPA Investigation Conducted
  • ER - Compliance Certification EPA Review
  • ES - EPA Conducted PCE/On-site
  • EX - EPA PCE/Off-site
  • PS - State Conducted PCE/On-Site
  • PX - State Conducted PCE/Off-site
  • SC - State Investigation Conducted
  • SR - Compliance Certification State Review
  • TE - EPA Required (O/O COND) Stack Test/not observed
  • TO - EPQ Required (0/0 COND) Stack Test/observed & reviewed
  • TR - State Required (O/O COND) Stack Test/not observed

Stack Tests:
Following a Clean Air Act source or performance stack test listed in the Compliance Monitoring History section, the "Finding" column includes the result of the stack test (Pass, Fail, Pending, or Blank) along with the pollutant tested if it is reported (please note that the pollutant tested is not required to be reported, although it is recommended).

A stack test, also referred to in EPA regulations as a performance or source test, measures the amount of specific regulated pollutant(s) or surrogates being emitted; demonstrates the capture efficiency of a capture system; or determines the destruction or removal efficiency of a control device used to reduce emissions at facilities subject to the requirements of the Clean Air Act. Stack tests are discussed in the Clean Air Act Stationary Source Compliance Monitoring Strategy (CMS) (pdf, 59KB), which provides recommendations to state and local environmental agencies to encourage national consistency in developing stationary source air compliance monitoring programs.

Title V Annual Compliance Certification (ACC):
Following a Title V Annual Compliance Certification Review or Title V Annual Compliance Certification Due/Received action, the Finding column includes the result of the review (In Compliance, In Violation, or Unknown), as well as whether any deviations were reported (Yes or No). Note: These actions may be performed and reported by a state permit authority or an EPA regional office, which also receives these documents from the permitted facilities as required in the permit and EPA Title V regulations. The CAA Stationary Source CMS provides details.

The results of performance stack tests conducted and of Title V Certification Reviews are required to be reported to the national program database, Air Facility System (AFS), based on the AFS Information Collection Request (pdf, 87KB). Regarding stack test results, as noted above, EPA does not require that the pollutant tested be reported. However, a violation of a major facility's allowable emission limit detected during a stack test may trigger a high priority violation status, according to the policy on the Timely and Appropriate Enforcement Response to High Priority Violations (HPV Policy) (pdf, 1.03MB).

Detailed information is available in the following documents:

Clean Water Act (CWA) - PCS

  • Compliance Evaluation (Non-Sampling)
  • Compliance Sampling
  • Performance Audit
  • Compliance Biomonitoring
  • Toxics Sampling Inspection
  • Diagnostic
  • Reconnaissance
  • Legal Support
  • Concentrated Animal Feeding Operation (CAFO)
  • Stormwater
  • Sanitary Sewer Overflow (SSO)
  • Sludge
  • Combined Sewer Overflow (CSO)

Clean Water Act (CWA) - ICIS-NPDES

  • ADR - Asbestos Demolition and Renovation
  • AER - Aerial Photography
  • AFD - AFO Defined
  • AFN - AFO Designation
  • AU1 - Audit
  • AU2 - Audit
  • CAI - Compliance Assistance Inspection
  • CBI - Biomonitoring
  • CCP - Citizen Complaint
  • CDI - Case Development
  • CEF - Full Evaluation
  • CEI - Evaluation
  • CEP - Partial Evaluation
  • CE2 - Evaluation
  • DIA - Diagnostic
  • FLP - Follow-Up
  • OPM - Operation and Maintenance
  • OSN - Non-Compliance Rate
  • OSV - On Site Visit
  • PIU - Non-Sampling
  • PRV - Plan Review
  • PSI - Sampling
  • RMT - Remote Sensing
  • ROS - Reconnaissance without Sampling
  • RWS - Reconnaissance with Sampling
  • SA1 - Sampling
  • SCE - Schedule Evaluation
  • TX1 - Toxics
  • TX2 - Toxics
  • WIT - Witness Response Drill

Resource Conservation and Recovery Act (RCRA)

  • CAC - Corrective Action Compliance Evaluation
  • CAV - Compliance Assistance Visit
  • CDI - Case Development Inspection
  • CEI - Compliance Evaluation Inspection
  • CSE - Compliance Schedule Evaluation
  • FCI - Focused Compliance
  • FRR - Financial Record Review
  • FSD - Facility Self Disclosure
  • FUI - Follow-Up Inspection
  • GME - Groundwater Monitoring Evaluation
  • NRR - Non-Financial Record Review
  • OAM - Operation and Maintenance Inspection

Italics indicate inspections that aren't included in official counts. See the Inspection Type introduction above for more information.

Emergency Planning and Community Right to Know Act (EPCRA) Section 313

  • EEA - EPCRA, Enforcement, Senior Environmental Employee (SEE) Conducted
  • EEF - EPCRA, Enforcement, Federal Conducted
  • EDA - EPCRA, Data Quality, Senior Environmental Employee (SEE) Conducted
  • EDF - EPCRA, Data Quality, Federal Conducted

Toxic Substances Control Act (TSCA)

  • 13I - Section 13 Importer Inspection
  • 2XP - Section 12 Export
  • 4CI - Section 4 Inspections
  • 4LP - Section 4 Good Laboratory Practices
  • 5CE - Section 5 Chemical Substance Exemption
  • 5CI - Section 5 Inspections
  • 5CF - Section 5 Order
  • 5FN - Section 5 Failure to Notify
  • 5PM - Section 5 Premanufacture Notice
  • 5SU - Section 5 Significant New Use Rule
  • 5TM - Section 5 Test Marketing Exemption
  • 6AA - Section 6 Asbestos Senior Environmental Employee (SEE) Conducted
  • 6AF - Section 6 Asbestos Federal Conducted
  • 6CI - Section 6 Inspections
  • 6DR - Section 6 Hexavalent Chromium
  • 6DX - Section 6 Dioxin
  • 6PA - Section 6 Polychlorinated Biphenyls Senior Environmental Employee (SEE) Conducted
  • 6PF - Section 6 PCB Federal Conducted
  • 6WA - Section 6 Asbestos Worker Protection Senior Environmental Employee (SEE)
  • 6WF - Section 6 Asbestos Worker Protection Federal
  • 8CI - Section 8 Confidential Inspections
  • 8CR - Section 8C Records Rule
  • 8HS - Section 8D Health and Safety Studies
  • 8LA - Section 8A Level A Rule
  • 8NV - Section 8 Inventory Rule
  • 8SR - Section 8E Substantial Risk
  • ACO - Asbestos School Hazard Abatement Act (ASHAA) Close Out
  • AEA - Asbestos Hazard Emergency Response Act (AHERA), Enforcement, Senior Environmental Employee (SEE) Conducted
  • AEF - Asbestos Hazard Emergency Response Act (AHERA), Enforcement, Federal Conducted
  • AMA - Asbestos, Model Accreditation Plan (MAP) Enforcement, Senior Environmental Employee (SEE)
  • AMF - Asbestos, Model Accreditation Plan (MAP) Enforcement, Federal
  • AON - Asbestos, Asbestos School Hazard Abatement Act Ongoing
  • APA - Asbestos, Asbestos School Hazard Abatement Act (ASHAA) Pre Award
  • AUN - Asbestos, Asbestos School Hazard Abatement Act (ASHAA) Unfunded
  • L2A - Lead, Section 402, Senior Environmental Employee (SEE)
  • L2F - Lead, Section 402, Federal
  • L4A - Lead, Section 404, Senior Environmental Employee (SEE)
  • L4F - Lead, Section 404, Federal
  • L6A - Lead, Section 406, Senior Environmental Employee (SEE)
  • L6F - Lead, Section 406, Federal
  • L8A - Lead, Section 408, Senior Environmental Employee (SEE)
  • L8F - Lead, Section 408, Federal
  • 6AS - Section 6 Asbestos State Conducted
  • 6CS - State Hexavalent Chromium
  • 6PS - Section 6 PCP State Conducted
  • 6WS - Section 6 Asbestos Worker Protection State
  • AES - Asbestos Hazard Emergency Response Act (AHERA), Enforcement, State Conducted
  • AMS - Asbestos, Model Accreditation Plan (MAP) Enforcement, State
  • L2S - Lead, Section 402, State
  • L4S - Lead, Section 404, State
  • L6S - Lead, Section 406, State

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

  • EUP - Experimental Use Permit
  • FTR - Section 7, Failure to Report
  • MPT - Import
  • RGA - Use Restricted/General Agriculture
  • RGN - Use Restricted/General Non-Agriculture
  • RRV - Records Review
  • UGA - Use General Agriculture
  • URA - Use General Non-Agriculture
  • URN - Use Restricted Non-Agriculture
  • XPT - Export
Lead Agency Identifies the lead agency (e.g., EPA, State) conducting the inspection.
Date The calendar date of the listed inspection.
Finding For CAA, includes results of source or performance stack tests or Title V certification review results when applicable; for CWA and RCRA, includes whether violations or compliance issues were found during an inspection, if entered into an EPA system.

Violation, noncompliance, significant noncompliance, and high priority violation are all terms used by the OTIS site to describe the facility status in regard to compliance with the law. In many cases, these terms reflect determinations made by EPA or states when conducting inspections or reviewing facility self-reports. These determinations assist the government in tracking resolution of violations through the enforcement process and do not necessarily represent a final adjudication by a judicial or administrative body. In such cases, these characterizations should be considered alleged violations.

 Compliance Summary Data
Statute

The name of the statute associated with each of the permits and identifiers linked to the facility. Only CAA, CWA, and RCRA are displayed in this section.

  • CAA = the Clean Air Act
  • CWA = the Clean Water Act
  • RCRA = the Resource Conservation and Recovery Act
Source ID

An alphanumeric field which has a unique value for each record/permit/site within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.

Current SNC/HPV

The current Significant Non-compliance (SNC) or High Priority Violator (HPV) status for the facility during the most current quarter reflects the time the records were extracted from the program data systems. SNC is used for RCRA and CWA, and HPV is used for CAA. Each program has its own specific criteria for making this determination. The value of "Yes" indicates the facility is in SNC or HPV for the permit or site in question and may pose a more severe level of environmental threat. The value of "No" indicates the permit or site is not considered in SNC or HPV. If the facility is Non-Federally Reportable within AFS or if it is classified as minor within PCS, the field reads "N/A". The value of N/A in this field indicates Not Applicable because compliance data for these facilities are not required to be reported to the national program database. When data are available, this field will indicate the compliance status for some minor facilities in ICIS-NPDES. Similar functionality will be added for PCS states soon. For minor facilities in ICIS-NPDES, N/A indicates that EPA's data system is not able to determine the facility-level compliance status based upon the information available. For the RCRA program, some hazardous waste facilities have activities in multiple states. When the SNC activity location is not the same as the state where the facility is located, the state of the SNC activity location is displayed in parentheses. A "Yes" by itself indicates that the facility has a SNC activity location in the state where the facility is located. A brief summary of each program's definition is shown below. However, these summaries are not meant to substitute for the complete definition, which can be found in the relevant guidance documents for a given program. Further information on each programmatic policy can be found on EPA's Web site at: CAA (PDF, 24 pp., 1.04 MB), RCRA (PDF, 14 pp., 145 KB) or CWA (PDF, 407 pp., 14.33 MB).

You will need Adobe Acrobat Reader, available as a free download, to view some of the files on this page. See EPA's PDF page to learn more about PDF, and for a link to the free Acrobat Reader.

Air High Priority Violation (HPV) Definition - The Air program uses the term HPV. HPV designations are made according to the December 22, 1998 memo: Issuance of Policy on Timely and Appropriate Enforcement Response to High Priority Violations. The following criteria can trigger HPV status:

  • Failure to obtain a Prevention of Significant Deterioration (PSD) permit
  • Violation of an air toxics requirement
  • Violation by a synthetic minor of an emission limit that affects the source's regulatory status
  • Violation of an administrative or judicial order
  • Substantial violations of a source's Title V obligations
  • Failure to submit a Title V permit application within 60 days of the deadline
  • Testing, monitoring, record keeping or reporting violations that substantially interfere with enforcement or determination of a facility's compliance requirements
  • Violation of an allowable emission limit detected during a source test
  • Chronic or recalcitrant violations, or
  • Substantial violations of 112 (r) requirements

The HPV designation is removed for a given source when all federal and state administrative and judicial action against the source is complete, the source has completed all requirements under the consent decree or final order including payment of all penalties and completion of supplemental environmental projects, and the source has been confirmed to be complying with the CAA.

The High Priority Violation (HPV) flag is reported in the Air Facility System (AFS), as of the last IDEA refresh of AFS. A 'YES' appears in the column to indicate that the facility has HPV status. Below is a list of violation codes within AFS that translate to HPV status.

  • B - Unaddressed, Shared Lead (EPA and State)
  • C - Addressed, Shared Lead (EPA and State)
  • E - Unaddressed, EPA Lead
  • F - Addressed, EPA Lead
  • S - Unaddressed, State Lead
  • T - Addressed, State Lead
  • X - Unaddressed, Lead Undetermined

The status of "Addressed" indicates that a formal action has been taken against the facility but its violations have not yet been resolved, or that a decision not to take a formal action has been made. For the CAA, violations are not considered resolved until the source is in full physical compliance and all penalties are paid. "Unaddressed" indicates that the facility's violations have not yet been addressed with a formal enforcement action or the decision to do so has not yet been made.

CWA Significant Non-Compliance (SNC) Definition - The National Pollutant Discharge Elimination System (NPDES) program uses the term SNC. SNC designations are made in accordance with the December 12, 1996 guidance document: A General Design for SNC Redefinition Enhancement in PCS. Most SNC designations are based on an automated analysis of Discharge Monitoring Reports (DMRs) that facilities with NPDES permits are required to submit on a monthly basis. The compliance designation of a facility in the PCS/ICIS-NPDES database is done using a mathematical formula that takes into account the amount, duration, and frequency of discharges in comparison with permit levels. In some instances facilities may be manually designated as SNC, even if the PCS/ICIS-NPDES data system does not automatically designate them as such. Examples of events that could result in the manual generation of a SNC code for a facility include: unauthorized discharges; failure of a Publicly Owned Treatment Works (POTW) to enforce its approved pretreatment program; failure to meet a construction deadline; failure to file a DMR; filing a DMR more than 30 days late; or violating any judicial or administrative order. Manually entered compliance data, if present, override machine-generated compliance data.

A facility may have multiple discharge points and different designations for each point. If any of these points show a SNC type code, then the overall facility status is listed as SNC, even if other discharge points are in compliance.

Removal of the SNC designation occurs once the facility's DMR reports show a consistent pattern of compliance with permit limits, or if EPA or a state agency issues a formal enforcement order to address the violations that resulted in the SNC designation and the facility has returned to compliance.

The most recent quarter for PCS/ICIS-NPDES is the most recent official quarter for which the quarterly status is available. This is usually 2 1/2 months after the quarter has ended. Thus, the most recent quarter in PCS/ICIS-NPDES is often not the same quarter as that for AFS and RCRAInfo.

The following are NPDES Quarterly Non-compliance Report codes that translate to SNC status:

  • S = SNC - an enforcement action has been issued, and the facility is not meeting its compliance schedule
  • E = SNC - effluent violations of monthly average limits (Technical Review Criteria and chronic)
  • X = SNC - effluent violations of non-monthly average limits (Technical Review Criteria and chronic)
  • T = SNC - compliance schedule reporting violation
  • D = SNC - reporting violation - non-receipt of DMR

RCRA Significant Non-Compliance (SNC) Definition - The RCRA program uses the term SNC. Any determination to classify a site as a SNC is made using the guidelines set forth in the December 2003 Hazardous Waste Civil Enforcement Response Policy. A site can be designated as a SNC if any of the following are found to exist: the site has been determined to cause actual exposure or has a substantial likelihood of causing exposure to a hazardous waste or constituent; is a chronic or recalcitrant violator; or deviates substantially from the terms of a permit, order or agreement, or from RCRA statutory or regulatory requirements. Under the RCRA program, the SNC designation is removed for a given site when the site is in full physical compliance with statutory and/or regulatory requirements.

Description The text description for the event that results in the permit or site being in Significant Non-compliance (SNC) or in High Priority Violation (HPV).
SNC Current As Of The most recent date or calendar year quarter of record maintained in the data system for which the Current SNC/HPV status applies. A quarter could be any of the following 3-month periods: January-March, April-June, July-September, or October-December.
Qtrs in NC (of 12) Count of the number of quarters, out of the last twelve quarters, in which the permit or site is considered either with violations, in non-compliance (NC) status, or in Significant Non-compliance (SNC) or High Priority Violation (HPV) status, as shown in the following section. A quarter is any of the following 3-month calendar periods: January-March, April-June, July-September, or October-December. Further violation and detailed compliance information can be found on ECHO's Frequently Asked Question page.

Violation, noncompliance, significant noncompliance, and high priority violation are all terms used by the ECHO site to describe the facility status in regard to compliance with the law. In many cases, these terms reflect determinations made by EPA or states when conducting inspections or reviewing facility self-reports. These determinations assist the government in tracking resolution of violations through the enforcement process and do not necessarily represent a final adjudication by a judicial or administrative body. In such cases, these characterizations should be considered alleged violations.


 Three Year Compliance Status by Quarter

The quarter is used as the measurement period because it is the shortest measurement period across all three statutes for which EPA receives non-compliance data from states. A quarter is any of the following 3-month calendar periods: January-March, April-June, July-September, or October-December. Violation information is displayed in a different manner for each statute. This is due to differences in how violations are tracked within each data system.

Definition of "Violation" - Non-compliance with one or more legally enforceable obligations by a regulated entity, as determined by a responsible authority. Included in this category are violations of legally enforceable obligations under pre-existing Final Orders (e.g., violations of compliance schedules included in enforcement orders). What does it mean if a facility is in violation?

The quarterly status measure may not reflect all actual non-compliance events in some cases. For example, EPA does not require national reporting for facilities with "minor" permits; thus, non-compliance at these facilities may not be completely shown in ECHO. For minor facilities, the authorized state may have information on violations not found in ECHO. Also, delays sometimes occur in entering non-compliance determinations into the database. Alternatively, in some cases, a facility may be shown to be in non-compliance while the facility has already remedied the underlying violation; this may occur because EPA or the state has not yet verified this. In other cases, the state or EPA may change its initial determination of non-compliance based on additional facts or discussions with the facility. Site users may report possible errors concerning non-compliance status from the facility report screen. Definitions for column headings are shown below.

Statute

Designation of the statute associated with each of the permits and identifiers linked to the facility:

  • CAA =the Clean Air Act;
  • CWA =the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery Act.
Source ID An alphanumeric field which has a unique value for each record/permit/site within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.
Quarterly Status Matrix

The quarterly status matrix of the Detailed Facility Report, displays compliance status data over the last three years of available data. Information is broken down into quarterly periods listed as QTR1 through QTR12 (most recent). A quarter is any of the following 3-month calendar periods: January-March, April-June, July-September, or October-December. Because quality assurance protocols differ among the data systems, the last twelve complete quarters of record may differ across EPA data systems (AFS, PCS and RCR). The periods referenced for each Source ID are listed below the QTR1 through QTR12 headings.

Air Compliance Status

HPV History (CAA) - The High Priority Violation (HPV) flag as reported in the Air Facility System (AFS), as of the last IDEA refresh of AFS. A blank in this column means that the facility is not currently a High Priority Violator (HPV). If more than one flag applies to a facility during a quarter, a prioritization is used to determine which code appears. The order of precedence is as follows:

  • B - Unaddressed, Shared Lead (EPA and State)
  • C - Addressed, Shared Lead (EPA and State)
  • E - Unaddressed, EPA Lead
  • F - Addressed, EPA Lead
  • S - Unaddressed, State Lead
  • T - Addressed, State Lead
  • X - Unaddressed, Lead Undetermined

The status of "Addressed" indicates that a formal action has been taken against the facility but its violations have not yet been resolved, or that a decision not to take a formal action has been made. For the CAA, violations are not considered resolved until the source is in full physical compliance and all penalties are paid. "Unaddressed" indicates that the facility's violations have not yet been addressed with a formal enforcement action or the decision to do so has not yet been made.

CAA Quarterly Status - For Clean Air Act (CAA) permits, the matrix provides quarterly status information for each air permit, and within each permit, the programs to which the facility or operation is subject. Within each CAA program, individual pollutants for which the facility is in current violation are listed on a separate line (slightly indented). The pollutant-specific information applies only to the most recent quarter of information, and is not aligned across the twelve quarter grid. In general, data relating to Federally-reportable facilities (see Facility Characteristics Section) is considered more reliable.

CAA programs include:

  • MACT - Maximum Achievable Control Technology;
  • MACT (SECTION 63 National Emission System for Hazardous Air Pollutants (NESHAPS));
  • SIP - State Implementation Plan;
  • SIP FEDERAL JURISDICTION;
  • PSD - Prevention of Significant Deterioration;
  • NSR - New Source Review;
  • NESHAP - National Emission System for Hazardous Air Pollutants;
  • NSPS - New Source Performance Standards;
  • TITLE V PERMITS ;
  • ACID PRECIPITATION;
  • CFC TRACKING - Chlorofluorocarbon requirement tracking;
  • Federally Enforceable State Operating Permit (FESOP) (NON-TITLE V);
  • NATIVE AMERICAN; and
  • NON-FEDERALLY REPORTABLE.

The following codes indicate that a CAA permit is considered out of compliance for the listed program:

  • V-NO SCH = In violation, no enforcement action has been issued specifying a compliance schedule
  • V-N SCH = In violation, an enforcement action has been issued, and the facility is not meeting its compliance schedule;
  • V-UNKNOWN = In violation, unknown w/regard to schedule;
  • V-EM&PRO = In violation, with regard to emissions and procedure (reporting requirements); or
  • V-PROCED = In violation, with regard to procedural compliance (reporting requirements).

Violation, noncompliance, significant noncompliance, and high priority violation are all terms used by the ECHO site to describe the facility status in regard to compliance with the law. In many cases, these terms reflect determinations made by EPA or states when conducting inspections or reviewing facility self-reports. These determinations assist the government in tracking resolution of violations through the enforcement process and do not necessarily represent a final adjudication by a judicial or administrative body. In such cases, these characterizations should be considered alleged violations.

The following codes indicate that a CAA permit is considered in compliance for the listed program:

  • UNKNOWN = Unknown status;
  • C-PROCED = In compliance with procedural requirements;
  • C-CEMS = In compliance - based on continued emissions monitoring (CEMS);
  • SEE OTHER = Present, see other program(s);
  • C-SOURCE = In compliance - based on source test;
  • C-INSP = In compliance - based on inspection;
  • C-CERT = In compliance - based on certification;
  • NO ST REG = No applicable state regulation;
  • C-SHUT DN = In compliance - shut down; and
  • S-MSched = Meeting compliance schedule.

To assist the user in understanding the above information, at the end of the Air Compliance Status section the following record keys are listed:

C=Compliance; V=Violation; S=Compliance Schedule.

CWA/NPDES Compliance Status

The compliance status for National Pollutant Discharge Elimination System (NPDES) dischargers is normally determined by the electronic comparison of discharge monitoring reports (DMRs) submitted by major facilities to permitted discharge limits. Both permit limits and discharge data must be present for the system to generate an accurate compliance status. The Detailed Facility Report presents the following information:

Non-compliance in Quarter
Indicates whether one or more violations occurred during a quarter. Any non-compliance event/violation from the four types described below will cause "Yes" to be displayed.

SNC/RNC Status (Significant Non-compliance/Reportable Non-compliance Status) for major facilities (or Facility Status for minor facilities)
EPA's official quarterly determination of whether violations at the facility warrant EPA/state review.

Note: The national program database calculates the severity of violations according to the Clean Water Act regulations, which have specific criteria specifying the duration, severity, and type of violations that rise to the level of Significant Noncompliance (SNC). The calculation of Category I Violations is equivalent to the SNC calculations, but because the violations occur at smaller dischargers (non-major), EPA does not classify the violations as "SNC". OTIS distinguishes between "SNC" and Category I because this has a bearing on the government response used to address the violation(s). Repeat SNC occurrences normally are addressed through formal enforcement actions, while Category I Violations are often addressed via informal processes.

The following codes are used on the Quarterly Non-compliance Report (QNCR) to indicate the facility's SNC/RNC or Category I/II status. If more than one code applies to a facility, a prioritization is used to determine which code appears. The order of precedence from most to least important is as follows:

  • S = SNC/Category I - an enforcement action has been issued, and the facility is not meeting its compliance schedule
  • E = SNC/Category I - effluent violations of monthly average limits (Technical Review Criteria and chronic)
  • X = SNC/Category I - effluent violations of non-monthly average limits (Technical Review Criteria and chronic)
  • T = SNC/Category I - compliance schedule reporting violation
  • D = SNC/Category I - reporting violation - non-receipt of DMR
  • N = RNC/Category II - reportable non-compliance
  • P = Resolved Pending - an enforcement action has been issued, and facility compliance with the action is pending final completion
  • R = Resolved - the facility has returned to compliance with its permit conditions, either with or without issuance of an enforcement action
  • C = Not considered in RNC/SNC based on manual review of data by state or EPA region. This manual override status is also indicated by a superscripted "m".
  • Blank = Not considered in RNC/SNC
  • N/A = EPA's data system is not able to determine the facility-level compliance status based upon the information available. This information may be available from a state database.

SNC/Category I categories are shown in RED, RNC/Category II categories are shown in ORANGE, On Schedule categories are shown in BLUE (these facilities are considered in compliance), and Compliance categories are shown in GREEN.

Facility-level (SNC/RNC) status is automatically generated based on DMR data. However, state or EPA manually entered compliance data, if present, override machine-generated compliance data. A CWA permit is considered noncompliant in a given quarter if a D, E, S, T, X, or N is presented in the SNC/RNC Status field. A code of C, P, or R indicates the facility is not considered in RNC or SNC (in addition to the automatically generated blank field).

In addition, a "U" (Undetermined) code may appear as the SNC/RNC Status for Oregon major facilities. As a pilot project for Oregon facilities only, the U code indicates that the facility-level compliance status for the facility is undetermined by PCS due to a lack of DMR data in the system. For information on the pilot project, see the Data Alerts page.

Effluent Violations
Effluent Violations by NPDES Parameter are listed for which the facility has exceeded its permitted limit once or more during the twelve listed quarters. Effluent exceedances are listed for the NPDES Parameter by Discharge point. Only violating parameters are shown.

Effluent violations are indicated by displaying the highest percentage by which the permit limit was exceeded for the quarter. Bold, large print indicates Significant Non-compliance (SNC) effluent violations. For unresolved SNC violations (e.g., violations with no government action against the facility), the table cell is shaded gray. It is possible for a facility to have effluent violations that do not rise to the SNC/RNC level. This occurs if the exceedances are not significantly over permit limits.

To the right of each parameter/chemical shown with a discharge violation, there is an indicator of what type of measurement was used to determine the violation. "Mnthly" stands for monthly. This means that the exceedance shown in that row was based upon a monthly average of readings submitted by the permittee. EPA generally believes that monthly averages are the most important, because the exceedance represents an average of many readings. "NMth" stands for non-monthly. This is generally a "maximum" amount read during the reporting period (and could indicate a spike that is not continuous). "Neither" denotes other measurements such as a minimum (e.g. pH could be in violation if below the permitted level). Please note that the exceedances shown in the table are the "worst" value within the quarter. Generally the permittee will report three times within the quarter (each month).

Compliance or Permit Schedule Violations
If a facility has been issued an enforcement action and is on a compliance schedule, all non-compliance events related to violations of that schedule in the past three years are listed under the Compliance Schedule Violations section. Text descriptions of the violation(s) are presented below the section heading (e.g., ACHIEVED LATE; NOTICE OF VIOLATION). If the facility is not on such a schedule or is on a compliance schedule but has no schedule violations, this section is not presented. Schedule violations are listed with the beginning and return-to-compliance dates across the twelve quarters. If the report shows a right arrow with no closing date, that means that the violation has not been resolved and continues to be active in the data system. If the violation started before the last three years of data and continues into the last three years, the beginning date is listed in QTR1. The most recent official quarter for PCS/ICIS-NPDES is usually available 2 1/2 months after the quarter has ended. While facility-level compliance status and effluent violations are displayed based on that schedule, compliance schedule violations are displayed as they are reported. Therefore, occasionally the compliance schedule event date will fall outside the date range of the final quarter displayed. For ICIS-NPDES data, please note that violations on the same day may be related to each other (for example, a violation for failure to file a report may be followed by a violation for late filing, which could be followed by a violation for failure to achieve schedule).

Single Event Violations
If the facility is identified as being in violation of CWA requirements, but this violation is not captured in the effluent exceedance section, these violations are presented in the section titled Single Event Violations. Text descriptions of the violation(s) are presented below the section heading (e.g., DISCHARGE WITHOUT A VALID PERMIT). If the facility has no single event violations in the past three years, this section is not presented. The date of each single event violation is listed in the table. Single event violations are often the result of inspection findings.

Violation, noncompliance, significant noncompliance, and high priority violation are all terms used by the ECHO site to describe the facility status in regard to compliance with the law. In many cases, these terms reflect determinations made by EPA or states when conducting inspections or reviewing facility self-reports. These determinations assist the government in tracking resolution of violations through the enforcement process and do not necessarily represent a final adjudication by a judicial or administrative body. In such cases, these characterizations should be considered alleged violations.

RCRA Compliance Status

RCRA Quarterly Status - All non-compliance events which would cause the RCRA site to be in non-compliance at some time in the past three years are listed under the Type of Violation section. A RCRA site is considered out of compliance for any quarter in which there is a violation date and no corresponding resolved date, and is considered out of compliance for each quarter thereafter until there is a resolved date. At the Facility Level Status, a site can be in Significant Non-compliance "SNC", In Violation "In Viol" or in Compliance "Compl". Some hazardous waste facilities have activities in multiple states. When the SNC activity location is not the same as the state where the facility is located, the state of the SNC activity location is displayed in parentheses. It is possible for the facility to have a SNC activity location in more than one state.

For the RCRA program, violations are listed with the beginning and return-to-compliance dates across the twelve quarters. If the report shows a right arrow with no closing date, that means that the violation has not been resolved and continues to be active in the data system. If the violation started before the last three years of data and continues into the last three years, the beginning date is listed in QTR1.

A RCRA site is considered to be in Significant Non-compliance in the most recent compliance quarter of record when there is actual exposure or a substantial likelihood of exposure to hazardous waste/constituents, is a chronic or recalcitrant violator; or a substantial deviation from the terms of a permit, order, agreement, or RCRA statutory or regulatory requirements.

Type of Violation - The RCRAInfo system uses codes which designate many different types of violation, depending on both the type of facility and the part of the site that had the violation. The violation types are nationally defined and the short description provided indicates the type of violation that allegedly occurred.

Data Quality Alert - If a violation was entered into the system many years ago, but was not properly turned off by the EPA or state, the violation will continue to appear on this report. If you suspect a resolved violation was not logged out of the system, please report this error.

Violation, noncompliance, significant noncompliance, and high priority violation are all terms used by the ECHO site to describe the facility status in regard to compliance with the law. In many cases, these terms reflect determinations made by EPA or states when conducting inspections or reviewing facility self-reports. These determinations assist the government in tracking resolution of violations through the enforcement process and do not necessarily represent a final adjudication by a judicial or administrative body. In such cases, these characterizations should be considered alleged violations.


Notices of Violation or Informal Enforcement Actions
  Notices of Violation are activities taken by EPA or the state that often precede a formal administrative or civil/judicial enforcement action. In many cases, a notice of violation causes a facility to correct problems and return to compliance. Many notices of violation are not escalated to formal enforcement action because the facility quickly corrects the problem(s) indicated in the notice. Activities entered under the following database codes are shown on the Detailed Facility Report.
Statute Designation of the statute associated with each of the permits and identifiers linked to the facility:
  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Recovery and Conservation Act;
Source ID An alphanumeric field, which is a unique value for each record/permit within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.
Type of Action Text description of type of notice of violation. The type of notice of violation and description are designated differently in each system, but may be equivalent. Under the CWA, the numerals appearing after the notice of violation type are not a part of the notice of violation. These numbers describe the type of violation (i.e., judicial, administrative, etc.) and are included with the text description of the violation.

CWA Informal Enforcement Actions (PCS Codes):
  • A8 - Notice of Violation/Potential Penalty (1)
  • 02 - Letter of Violation - Other (1)
  • 03 - Warning Letter
  • 05 - Phone Call
  • 07 - Pre-enforcement Meeting
  • 08 - Letter of Violation - Effluent (1)
  • 10 - 308 Letter
  • 15 - Written Information Request
  • 20 - Notice of Violation (NOV)
  • 61 - Notice of Potential Penalty (1)
  • 91 - Enforcement Notice Letter (1)
  • 92 - Pre-Enf Conference Letter (1)
  • 93 - Enf Conference Letter (1)
  • 98 - Notice of Violation, Informal (1)
  • 99 - Notice of Noncompliance, Informal (1)
In many cases, EPA does not require national reporting for facilities with "minor" permits, so NOVs at these facilities may not be presented in this table.

1. These Informal Enforcement Action Codes are no longer used, but are still shown on the DFR for historical purposes. These Informal Enforcement Action Codes cannot be entered into the databases under the PCS definitions.

CWA Informal Enforcement Actions (ICIS-NPDES Activity Type Code):
  • INF - Administrative Informal

CAA Informal Enforcement Actions (AFS National Action Types):
  • 5A - EPA pre-NOV letter sent
  • 6A - EPA NOV issued
  • 7C - State NOV issued

RCRA Informal Enforcement Actions (RCRAInfo Action Series): Any code in the following series
  • 110 - Verbal Informal
  • 120 - Written Informal
Note: The types of action noted above are nationally defined by EPA. Other types of action shown in the report are defined or maintained by EPA regions or state agencies.
Lead Agency The lead agency responsible for issuing the notice of violation.
Date Effective date of the listed notice of violation. Notices of violation listed within the last five years are included.

 Formal Enforcement Actions
The Formal Enforcement Actions section of the Detailed Facility Report provides the federal and state formal enforcement actions that have been entered into federal data systems for each facility over the past five years. The last five years will include data from the twenty most recently completed quarters, plus data from the current quarter up until the refresh date. Enforcement actions under the Clean Air Act (CAA); Clean Water Act (CWA); Resources Conservation and Recovery Act (RCRA); Emergency Planning and Community Right-to-Know Act Section 313 (EPCRA); Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and Toxic Substances Control Act (TSCA) over the past five years are included. . Federal and state enforcement actions are identified from each of the program databases (AFS, PCS, NCDB, and RCRAInfo) via the Integrated Data for Enforcement Analysis (IDEA) system. Enforcement actions and penalties from the Federal Enforcement Docket, as maintained in EPA's Integrated Compliance Information System (ICIS), as well as state enforcement actions from ICIS-NPDES, are displayed in the Formal Enforcement Actions - ICIS section. This section does not include data regarding enforcement referrals or criminal enforcement actions.
Statute

Designation of the statute associated with each of the permits and identifiers linked to the facility:

  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery
  • EPCRA = Emergency Planning and Community Right-to-Know Act;
  • FIFRA = Federal Insecticide, Fungicide, and Rodenticide Act; and
  • TSCA = Toxic Substances Control Act. Act;
Source ID An alphanumeric field, which is a unique value for each record/permit within each data system. These identifiers are for tracking purposes in the individual data systems. The identifier used in the federal AFS database is typically different from the permit number issued to the facility.
Type of Action Text description of type of enforcement action. The type of action and description are designated differently in each system, but may be equivalent. Under the CWA, the numerals appearing after the enforcement action type are not a part of the enforcement action. These numbers describe the type of action (i.e., judicial, administrative, etc.) and are included with the text description of the action. Entries in italics are not "formal" actions under the PCS definitions but are either the initiation of an action or penalties assessed as a result of a previous action.

CWA Formal Enforcement Actions (PCS Codes):
  • AE - Penalty AO Issued by State
  • AF - Pretreat Penalty AO Issued by State
  • AG - AO Stipulated Penalty*
  • A1 - NPDES Penalty AO Category I
  • A3 - NPDES Penalty AO Category II
  • A5 - Pretreatment Penalty AO Cat. I
  • A7 - Pretreatment Penalty AO Cat. II
  • B2 - CWA 404 Penalty AO Class I Init
  • B4 - CWA 404 Penalty AO Class II Init
  • C1 - Time Schedule Order
  • C2 - Expedited Settlement-Admin. 2
  • C3 - Expedited Settlement-Penalty P
  • 21 - Administrative Order
  • 22 - Administrative Consent Order
  • 23 - 309 (A) (5) (A) Order (1)
  • 24 - 309 (A) (6) (1)
  • 25 - Consent Decree
  • 35 - Stipulation Court Order (1)
  • 36 - Civil Action Filed
  • 37 - Trial Court Order
  • 38 - Criminal Action Filed
  • 55 - Compliance Order with Penalty (1)
  • 56 - MCP Schedule AO-EO (1)
  • 58 - MCP Schedule Consent Decree (1)
  • 62 - CCP Schedule AO-EO (1)
  • 63 - Compliance Order (1)
  • 68 - Comp Order/Notice Potent Penalty (1)
  • 71 - Pretreatment Consent Decree
  • 72 - Pretreatment AO
  • 75 - Fed Facility Comp Agreement
  • 76 - AO-MCP (1)
  • 79 - Judicial Administrative Decree (1)
  • 80 - Pollution Control Board EO (1)
  • 81 - Final Order of the Board (1)
  • 82 - Notice of Noncompliance (1)
  • 83 - Notice of Violation, Formal (1)
  • 84 - Stip/Order of Remedial Action (1)
  • 85 - Final Order of Abatement (1)
  • 86 - Stipulation Agreement (1)
  • 87 - Dir. Final Findings/Order (1)
  • 88 - Enforcement Conf Agreement (1)
  • 89 - Order of Suspension (1)
  • 90 - Order of Revocation (1)
  • 96 - Administrative Enforcement Order (1)
  • 97 - Emergency Order, Governor

* These are not "formal" actions under the PCS definitions but are either the initiation of an action or penalties assessed as a result of a previous action.

1. These Formal Enforcement Action Codes are no longer used, but are still shown on the DFR for historical purposes. These Enforcement Action Codes cannot be entered into the databases under the PCS definitions.

CWA Formal Enforcement Actions (ICIS-NPDES Codes):
  • AFR - Administrative - Formal
  • JDC - Judicial

CAA Formal Enforcement Actions (AFS National Action Types):

  • 1B - 113 (D) (4) Innov. Tech. Order approved/issued (2)
  • 2D - State court consent decree
  • 6B - EPA court consent decree
  • 7A - Notice of noncompliance (Section 120) (2)
  • 7E - EPA 167 order
  • 7F - 113D APO complaint filed
  • 8A - EPA 113 (A) order issued
  • 8C - State administrative order issued
  • 9A - 113(D) delayed compliance order approved/issued (2)
2. These Formal Enforcement Action Codes are no longer used, but are still shown on the DFR for historical purposes. These Enforcement Action Codes cannot be entered into the databases under the AFS definitions.
RCRA Formal Enforcement Actions (RCRAInfo Action Series):
Any code in the following series:
  • 210 - Initial 3008(a) Compliance Order
  • 220 - Initial Imminent and Substantial Endangerment Order
  • 230 - Initial Monitoring, Analysis, Test Order
  • 240 - Initial 3008(h) I.S. CA Order
  • 250 - Field Citation
  • 310 - Final 3008(a) Compliance Order
  • 320 - Final Imminent Hazard Order
  • 330 - Final Monitoring, Analysis, Test Order
  • 340 - Final 3008(h) I.S. CA Order
  • 380 - Super CA/FO
  • 510 - Initial Civil Judicial Action for Compliance and/or Monetary Penalty
  • 520 - Initial Civil Action for Imminent and Substantial Endangerment
  • 530 - Initial Judicial Action for Corrective Action
  • 610 - Final Civil Judicial Action for Compliance and/or Monetary Penalty
  • 620 - Final Civil Action for Imminent and Substantial Endangerment
  • 630 - Final Civil Judicial Action for Interim Corrective Action
Note: The types of action noted above are nationally defined by EPA. Other types of action shown in the report are defined or maintained by EPA regions or state agencies.

EPCRA 313, FIFRA, TSCA (NCDB):
Any administrative or judicial action.
Lead Agency The lead agency responsible for the enforcement action.
Date Effective date of the listed enforcement action. Enforcement actions listed within the last five years.
Penalty Dollar amount of penalty assessed, when available. Amount is the final penalty unless otherwise noted in the Penalty Description field. In PCS, state administrative penalties are not required to be input to the system.
Penalty Description Further details on listed enforcement action or penalty, when available (only from RCRAInfo).

 Formal Enforcement Actions - ICIS

The Formal Enforcement Actions - ICIS section of the Detailed Facility Report provides the federal civil enforcement actions that have been entered into the Integrated Compliance Information System (ICIS) for each facility over the past five years, as well as state formal enforcement actions for the CWA NPDES program. The last five years will include data from the twenty most recently completed quarters, plus data from the current quarter up until the IDEA refresh date. Federal enforcement actions under the Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund), Toxic Substances Control Act (TSCA), Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Safe Drinking Water Act (SDWA), and Marine Protection, Research, and Sanctuaries Act (MPRSA) are included. State enforcement actions under NPDES are included for states using ICIS-NPDES.

Federal enforcement actions and penalties included in this section of the report may be duplicative of the federal actions and penalties shown in the Formal Enforcement Actions section for actions under CAA, CWA, and RCRA. Federal enforcement actions and penalties from ICIS are not included in the Inspection and Enforcement Summary Data section of the Detailed Facility Report.

Primary Law/Section

Designation of the primary statute associated with the case and the section of the law violated by the defendant(s) and cited in the action:

  • CAA = the Clean Air Act;
  • CWA = the Clean Water Act;
  • RCRA = the Resource Conservation and Recovery Act;
  • CERCLA = the Comprehensive Environmental Response, Compensation, and Liability Act (Superfund);
  • EPCRA = the Emergency Planning and Community Right-to-Know Act Section 313;
  • TSCA = the Toxic Substances Control Act;
  • FIFRA = the Federal Insecticide, Fungicide, and Rodenticide Act;
  • SDWA = the Safe Drinking Water Act; and
  • MPRSA = the Marine Protection, Research, and Sanctuaries Act.
Case Number

An alphanumeric field which is a unique identifier for each case. EPA regions keep a log of the case numbers so that each new case is entered using the next incremental Case Number. For federal cases, the Case Number must be entered in the rr-yyyy-nnnn format, where:

  • rr = the Responsible Office for the case, with possible values being 01 through 10 (the EPA regional offices), and HQ (EPA Headquarters)
  • yyyy = the Fiscal Year during which the case is initially developed
  • nnnn = the sequence number, with possible values from 0000 through 9999
Case Type

A three-character code that indicates the action type at the case level:

  • JUD = Consent decree or court order resolving a civil judicial action
  • APO = Administrative penalty order with or without injunctive relief
  • ACR = Superfund administrative order for cost recovery
  • FFC = Federal facility compliance agreement (not including RCRA matters)
  • RC = Field Citation
  • ACO = Administrative Compliance Orders
Case Name An alphanumeric field that contains the name assigned to the case by the lead attorney. Generally the primary defendant's name or the facility name is used as the case name.