Using ICIS Reports to Identify Activities that May Not Have the Correct or Complete National Enforcement Initiative Indicator(s)

This document describes the steps to review National Enforcement Initiative (NEI) cases for possible “flagging” issues. Two ICIS reports are used: 1. “DQR - Initiated and Concluded National Initiative cases All”, and 2. “DQR - National Initiative & Program QA”.

The first report can be used to identify initiated, judicial complaint filed, or concluded NEI cases where the “OECA National Priority” field is not up-to-date on the ICIS basic information screen or on the ICIS final order screen. In addition, this report can be used to identify NEI cases with one of the “CA Only” priorities is selected, as well as cases with multiple NEIs selected.

The second report can be used to identify initiated and concluded cases where a program violated is either CAFO, CSO, SSO, MS4, or PSD, but the “OECA National Priority” field is blank on the ICIS basic information screen and on the ICIS final order screen.

Please contact David Sprague at 202-564-4103 or [email protected] if you have questions or need assistance.

Review using the “DQR - Initiated and Concluded National Initiative cases All” report Running Report: Run the “DQR - Initiated and Concluded National Initiative cases All” report located in the ICIS “Federal Enforcement and Compliance Reports / Data Quality Reports” folder for the fiscal year and quarter(s) to be reviewed and download the results to your PC, or shared drive.  Download the results in Excel output format, so you will be able to manipulate the output using Excel.  If desired, also download the report in Adobe Acrobat format, so you will be able to see the report headers (titles, refresh date, etc.).

Initiated (either Administrative Complaint or Referral to DOJ) NEI cases: The cases on the “Initiation in FY” worksheet have a date in the fiscal year and quarter(s) for which the report was run in the “Admin Compt Issued Date” (for administrative cases) or the “Referred to DOJ Date” (for judicial cases). Review this worksheet for cases where the “Initiation OECA National Priorities” information is blank, or incorrect. For these cases, the NEI for the fiscal year in which the case was initiated should be added/corrected in the “OECA National Priority” field on the basic information screen in ICIS.

1FY 2014 Reporting Plan Judicial Complaint Filed NEI cases: The cases on the “Jud Compl Filed in FY” worksheet have a date in the fiscal year and quarter(s) for which the report was run in the “Judicial Complaint Filed Date” field. Review this worksheet for cases where the “Initiation OECA National Priorities” listed do not have a value for the fiscal year for which the report was run. For these cases, the NEI for the fiscal year the judicial complaint was filed should be added to the “OECA National Priority” field on the basic information screen. When adding the NEI to the basic information screen, the control key must be pressed , so existing values in the “OECA National Priority” field are not accidentally removed.

Concluded NEI cases: Review the “Concluded - NEI blank” worksheet for cases where the “Final Order Year OECA National Priorities” information is blank. For these cases, the NEI for the fiscal year in which the case concluded should be added to the “OECA National Priority” field on the final order screen. If applicable, the “Priority” field should also be updated for the appropriate environmental benefit amounts and for the “Cost of Complying Action/Injunctive Relief” on the Complying Action/Inj. Relief screen.

 Note: determine if any of the cases on the “Concluded - NEI blank” worksheet have a correct value for “Final Order Year OECA National Priorities”, in addition to blank, by reviewing these cases in the “Details – All” worksheet. Any cases that do have a correct value for “Final Order Year OECA National Priorities” do not have to be updated in ICIS.

Compliance Assistance (CA) Only NEI cases: Review the “CA Only QA list” worksheet for initiated and/or concluded NEI cases where the “Initiation OECA National Priorities” and/or “Final Order Year OECA National Priorities” listed are one of the “CA Only” priorities. Since these are enforcement actions, a “CA Only” initiative should never be selected. The "CA Only" initiative(s) should be changed to the appropriate enforcement action initiative(s) or removed.  Changes to the “Initiation OECA National Priorities” should be made to the “OECA National Priority” field on the basic information screen.  Changes to the “Final Order Year OECA National Priorities” should be made to the “OECA National Priority” field on the final order screen.  If applicable, the “Priority” field should also be updated for the environmental benefit amounts and for the “Cost of Complying Action/Injunctive Relief” on the Complying Action/Inj. Relief screen.

Multiple NEI cases: Review the “Details – All” worksheet for cases with multiple NEIs selected for the same fiscal year (for example, “2014 - Air Toxics – Flares” and “2014 - Air Toxics – LDAR”) in either “Initiation OECA National Priorities” or “Final Order Year OECA National Priorities”. Review these cases to confirm that the multiple initiatives are correct.

2FY 2014 Reporting Plan  Changes to the “Initiation OECA National Priorities” should be made to the “OECA National Priority” field on the basic information screen.  Changes to the “Final Order Year OECA National Priorities” should be made to the “OECA National Priority” field on the final order screen.  If applicable, the “Priority” field should also be updated for the environmental benefit amounts and for the “Cost of Complying Action/Injunctive Relief” on the Complying Action/Inj. Relief screen.

Review using the “DQR - National Initiative & Program QA” report Running Report: Run the “DQR - National Initiative & Program QA” report located in the ICIS “Federal Enforcement and Compliance Reports / Data Quality Reports” folder for the fiscal year and quarter(s) to be reviewed and download the results to your PC, or shared drive.

Cases with Missing NEIs: The cases on the “NEIs Blank” worksheet show initiated and concluded cases in the fiscal year and quarter(s) for which the report was run where a program violated is either CAFO, CSO, SSO, MS4, or PSD and the “Initiation OECA National Priorities” information is blank and the “Final Order Year OECA National Priorities” information is blank. If appropriate, NEIs should be selected for these cases.

 Changes to the “Initiation OECA National Priorities” should be made to the “OECA National Priority” field on the basic information screen. In addition, for initiations, ensure NEI selections are made for both the referral fiscal year and the complaint filed fiscal year, if applicable.

 Changes to the “Final Order Year OECA National Priorities” should be made to the “OECA National Priority” field on the final order screen.

 If applicable, the “Priority” field should also be updated for the environmental benefit amounts and for the “Cost of Complying Action/Injunctive Relief” on the Complying Action/Inj. Relief screen.

3FY 2014 Reporting Plan