Corrective Action Orders Entered into ICIS and RCRAInfo
Different data needs of EPA’s enforcement and clean-up programs result in double-data entry of federal enforcement actions. As a reminder, federal RCRA enforcement data is maintained in two EPA databases. ICIS is OECA’s database of record for federal enforcement actions, and RCRAInfo is the RCRA program database of record for clean-up information, including corrective action pipeline events that are associated with a state/federal enforcement action or a permit. It is critical that the RCRA Corrective Action federal enforcement actions be entered timely and completely into both databases.
In FY 2010, based on regional feedback OSRE identified 22 RCRA corrective action enforcement actions entered into ICIS and only three of those orders were entered into RCRAInfo. Of the three orders in RCRAInfo there were discrepancies between the ICIS and RCRAInfo records. Similar problems were found during a review of FY 2011 federal enforcement data. Beginning in FY 2011 new federal corrective action law section "violated" choices were added to ICIS to better identify RCRA Corrective Action orders from other RCRA orders. Double data entry must continue with both databases; however, now it is easier to review the corrective action data in ICIS. OSRE plans to continue reviewing the FY 2012 federal enforcement data in ICIS and RCRAInfo, and share any discrepancies with the regions.