From: John Dombrowski, Director
Enforcement, Targeting and Data Division (ETDD)
Office of Compliance (OC)
Office of Enforcement and Compliance Assurance (OECA)
To: ICIS FE&C and ICIS-NPDES Contacts and Coordinators
Subject: ICIS Release v5.1 (CCDS Enhancements)
I'm pleased to announce that, over this past weekend, we upgraded the Integrated Compliance Information System (ICIS) to support the FY2012 Case Conclusion Data Sheet (CCDS) Guidance. The enhanced screens in ICIS implement the new approach for how information is collected on the results achieved from concluded federal enforcement cases. The new approach, as described in the guidance, establishes a framework for more consistent use of methods to calculate environmental benefits. The three categories previously used to describe environmental benefits are now replaced by four new remedy categories, which are: (1) Removal and Restoration, (2) Reduction of On-going Releases, (3) Prevention of Future Releases, and (4) Work Practices.
The ICIS environmental benefit screens have been completely redesigned to streamline the data entry process for this new approach. Highlights include: the ability to identify the Core/National/Regional Priority on the Final Order screen, a more flexible complying action selection process, use of a single injunctive relief amount rather than having to split amounts between complying action categories, and a new complying action/injunctive summary screen that allows easy access to manage the information. The final CCDS Guidance will soon be posted online, but in the interim please feel free to contact Donna Inman (Inman.Donna@epa.gov, 202-564-2511) if you have any CCDS policy questions, or contact ICIS Customer Support (ICIS@epa.gov, 202-564-7756) for a copy of the guidance.
In addition to making these significant CCDS enhancements, this release also resolves a problem concerning the generation of the new "U" and "V" Status Codes for Reportable Non-Compliance (RNC), which were put into production back on October 2, 2011. Several very alert and helpful members of our user community informed us of one problem and one previously-overlooked logic scenario, which are addressed in this release as follows:
- RNC Status Code "U" issue and fix:
- · When the current Compliance Tracking Status (CTS) is off, status code U is automatically generated for minor permits.
- · The problem was that the logic used the most recently-generated CTS and whenever a permit is reissued, CTS is turned off. Thus, the most recently-generated CTS could come from a reissued permit. If the most recent CTS came from the reissued permit, RNC Status U was falsely generated.
- · The ICIS logic has been changed to look for the most recent CTS within the current permit.
- RNC Status Code "V" issue and fix:
- · Discharge Monitoring Report (DMR) non-receipt violations generated without RNC detection within the current Quarterly NonCompliance Report (QNCR) quarter generate the RNC status code V.
- · The logic omission was failing to take into account DMR non-receipt violations where the DMR has been received within the current QNCR quarter
- · New logic has been added to ICIS to account for the scenario in which DMRs are received within the current QNCR quarter.
- · To date, there have not been any false RNC Status Code V's generated because of the prior logic omission.
If you have any questions about either the new CCDS functionality or the resolution of the RNC Status code issues, please contact ICIS Customer Support at ICIS@epa.gov or 202-564-7756.