Indicators

This page includes descriptions and additional background information for each of the facility-specific indicators included in SFIP. The indicators are included to convey important information relating to facility size, past as well as current compliance and enforcement status, chemical releases, pollutant spills and demographic information regarding the surrounding population. Many of the indicators explained below are aggregated from raw data contained in EPA databases. To the extent possible, SFIP allows data users to view the raw data in order to give more context to broader aggregate indicators. For example, if a facility is shown as having one closed enforcement action, the underlying data provide details on the event to which the enforcement action pertained, when it happened, and whether an associated penalty resulted and the amount. This layered approach allows for comparative analysis, and more thorough inquiry regarding individual facility records.

The SFIP indicators are compiled and generated primarily from EPA's Integrated Data for Enforcement Analysis (IDEA) system. This system provides the capability to integrate separate EPA databases for the purpose of providing information across many regulatory programs. To make the proper connections across data systems using different facility identifiers, complicated automated and manual data reconciliation necessitated that the work under SFIP be constrained to a defined number of data systems. Consequently, SFIP currently focuses primarily on EPA data relating to the Toxics Release Inventory (TRI) program, and air, water, and hazardous/solid waste statutes. There are a number of other federal statutory requirements which are not included in the compliance history of the facilities covered by this project. These include, for example, requirements under Superfund (Comprehensive Environmental Response, Compensation and Liability Act) and the Safe Drinking Water Act. To the extent possible, SFIP will incorporate other important data from other programs in the future.

NOTE: The standardized reports available through SFIP array indicators are arranged in such a way as to separate the compliance and enforcement data from information not related to compliance (i.e., chemical release, production or demographic data). TRI chemical release information is provided for each reporting facility. It is not a measure of compliance as the reported releases are typically permissible under current laws.

NOTE: SFIP links the permits and identification numbers associated with those facilities with active operations included in SFIP. Due to statutory requirements and the physical layout of particular facilities, there are instances where a permit or identification number covers other operations located on the same site. For example, the Toxics Release Inventory program requires facilities to estimate chemical releases and transfers from all of their operations on a contiguous property. Consequently, the TRI release and transfers estimates associated with a particular refinery may also include releases and transfers from other operations, such as organic chemical production, located on the same property.

Inspections: The number of state/local and federal inspections that have occurred at each facility examined under the project.

Under SFIP, EPA provides the number of inspections that have occurred under the Clean Air Act (CAA), the Clean Water Act (CWA), and the Resource Conservation and Recovery Act (RCRA) over the past two years. Inspections include all federal and state/local inspections that are reported into federal data systems. The three major systems are: Resource Conservation and Recovery Information System (RCRAInfo) for hazardous waste management inspections; Aerometric Information Retrieval System (AIRS) for air inspections; and the Permit Compliance System (PCS) for water inspections. This indicator is used to show inspection presence. Underlying data, such as the date and type of inspection performed, are presented on the Detailed Facility Report.

EPA has recently implemented a new Compliance Monitoring Strategy for the Clean Air Act that replaces the previous levels of inspections and instead institutes three categories of compliance monitoring: Full Compliance Evaluations, Partial Compliance Evaluations, and Investigations. Each of these categories is defined below:

Full Compliance Evaluation - A Full Compliance Evaluation is a comprehensive evaluation of the compliance status of a facility. It addresses all regulated pollutants at all regulated emission units. Furthermore, it addresses the current compliance status of each emission unit, as well as the facility's continuing ability to maintain compliance at each emission unit.

Partial Compliance Evaluation - A Partial Compliance Evaluation is a documented compliance assessment focusing on a subset of regulated pollutants, regulatory requirements, or emission units at a given facility. A Partial Compliance Evaluation should be more comprehensive than a cursory review of individual reports. It may be conducted solely for the purpose of evaluating a specific aspect of a facility, or combined over the course of a year (or up to three years at mega-sites) to satisfy the requirements of a Full Compliance Evaluation.

 

Investigation - An Investigation can be distinguished from the other two categories in that generally it is limited to a portion of a facility, is more resource intensive, and involves a more in-depth assessment of a particular issue. It usually is based on information discovered during a Full Compliance Evaluation, or as the result of a targeted industry, regulatory or statutory initiative. Also, an Investigation often requires the use and analysis of information not available in EPA data systems. It is best used when addressing issues that are difficult to evaluate during a routine Full Compliance Evaluation because of time constraints, the type of preliminary field work required, and/or the level of analytical expertise needed to determine compliance.

NOTE: The inspection data within SFIP are limited to what EPA collects at the federal level. Thus, there may be inspections at the state/local level that are not required to be reported to the federal systems.

Historical Noncompliance: The number of quarterly periods with one or more identified violation or noncompliance during the eight quarterly periods over the last two years.

This indicator is designed to show whether individual facilities are generally in compliance, or in noncompliance over a period of two years. The indicator examines whether instances of noncompliance occurred or continued from previous periods at facilities within the past eight quarterly measurement periods. Each quarter equals three months; therefore eight quarters equals 24 months, or two years. Under CAA, CWA and RCRA, SFIP indicates historical noncompliance as reported into national data systems by the state/local agencies and EPA Regions. Underlying information is available for each facility, which can be used to determine the type of violation or noncompliance that is counted in the aggregate statistics, and whether multiple events occurred.

The quarter is used as the measurement period because it is the shortest measurement period across all three statutes in which EPA receives noncompliance data from states. The methodology used for this indicator does not reflect all potential noncompliance events because: 1) state/local data may not have been entered into or required by federal data systems; 2) EPA, the state or local regulatory agency may not have visited the facility to determine the compliance status; or 3) facilities may be out of compliance with other statutes and programs that are beyond the three programs included in this project. In many cases, EPA does not require national reporting for facilities with "minor" water permits (which establish limits for pollutants such as oil and grease), so noncompliance at these facilities may not be completely captured in the SFIP data. When possible, EPA provides an indication as to when data are not available; however, in some cases when the compliance status is unknown, facilities may be shown to be in compliance.

Given the available data collected, this indicator provides a screening-level indicator of historical non-compliance with the notes listed above. It is important to note that this aggregate indicator is not designed to distinguish the severity of the violation or noncompliance. More detailed historical noncompliance information (e.g., pollutants over permit limits, reporting violations, dates) is available through SFIP on the Detailed Facility Report.

NOTE: The compliance history data within SFIP are limited to what EPA collects at the federal level. Thus, there may be quarterly noncompliance information maintained at the state/local level that are not required to be reported to the federal systems.

NOTE: This indicator does not reflect the duration of noncompliance within a quarterly period in which a facility is considered out of compliance. Thus, there may be an instance where the facility is out of compliance for a period that is less than the entire quarter but is flagged for being in violation for the quarter. The duration of violation may be ascertained by reviewing the underlying data reports that indicate the starting and ending dates of violations or noncompliance events.

NOTE: When the Agency has made a determination that a facility is not in compliance, a facility may be put on an enforceable compliance schedule to bring them into compliance with permit or regulatory requirements. In this data system, a facility is considered to be "in compliance" if it is meeting a compliance schedule even though it is not in compliance with all underlying regulatory and permit requirements. Users can see whether the facility has been, or is, on a compliance schedule under any program in the Detailed Facility Report.

Permit Exceedances - Clean Water Act: The number of times facilities report their water discharges, and how often these discharges exceed permitted levels.

This indicator merges information on both pollutant release and compliance history. The indicator shows the number and frequency of self-reported water monitoring events that exceed permitted limits under the CWA. This indicator is limited to the CWA as there are no similar indicators available nationally for the CAA and RCRA.

The CWA requires that EPA or the states set limits through permits under the National Pollutant Discharge Elimination System (NPDES) on the amount of pollutants that facilities may discharge into a waterbody. Limits for these discharges are set according to national technology-based standards, and the conditions of the waters that receive the discharge based on state water quality standards. Depending upon the reporting period specified in a facility's permit, a facility may be required to submit monthly, bi-monthly, quarterly, semi-annual, annual, or bi-annual monitoring reports for a parameter. A parameter can be a chemical, such as cadmium; a pollutant, such as total suspended solids; or a characteristic of the wastewater, such as pH or temperature. Different reporting periods may be specified for a single permitted parameter based on locations within single or multiple discharge pipes.

SFIP tracks four indicators for pollutant releases that exceed permitted levels:

• the total number of Permit Compliance System (PCS) parameters monitored across all pipes and NPDES permits maintained by a regulated facility;
• the total number of those parameters for which there is at least one exceedance of the permitted limit in the past two years;
• the total number of reports submitted in the past two years; and
• the total number of those events which exceeded the permitted limit.
  

The display of permit exceedances at the parameter level is based solely on the self-reported monitoring results in PCS, and does not involve any calculations based on the frequency or severity of violations within a specified period of time. This indicator was added in response to stakeholder comments.

NOTE: These four indicators apply to all PCS parameters (e.g., chemical pollutants as well as temperature) since it is not currently possible to differentiate among classes of parameters using the PCS data stored in IDEA.

Current Significant Noncompliance Indicator/High Priority Violation Indicator (SNC/HPV): The most recent status for the facility with regard to whether more severe noncompliance has been detected.  SNC is used for CWA and RCRA, and HPV is used for CAA.

In contrast to the historical noncompliance indicator explained above, SNC or HPV provides an indication of whether violations or noncompliance events at a given facility may pose a more severe level of environmental threat. SFIP uses the significant noncompliance indicators or high priority violation indicators defined by each individual program. The aggregate indicator shown within SFIP indicates a "yes" or "no" variable for SNC or HPV under the CAA, CWA, and RCRA for the most recent publicly available data.

NOTE: EPA does not maintain historical SNC/HPV data in all data systems, so this indicator is only used for the most current period.

Air Program HPV - 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 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 sources 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

In the air program, the HPV designation is removed for a given facility once the facility has demonstrated that it has resolved the violation that led to the HPV listing, or when EPA or the state agency issues a formal enforcement action to address the HPV violation.

Water Program SNC - A facility will be classified in SNC if it meets any of the following three conditions: submitting a major report 30 days or more past the due date, failure to meet a major schedule by 90 days or more, or a major exceedance of selected effluent limits. The PCS data system is set up to anticipate data from the permitee on effluent discharges, reports and schedules as well as to calculate violations. In addition, the facility has an obligation to notify the regulatory agency when it has violations or that compliance has been achieved. A facility may also be placed in SNC if it fails to comply with the requirements of any enforcement order taken against it. In PCS, a facility is removed from SNC status when either the conditions which resulted in its categorization as SNC no longer exist or a formal enforcement action regarding the violation has been taken.

RCRA Program SNC - In RCRAInfo, a facility is classified as being in SNC if it has caused actual exposure or a substantial likelihood of exposure to hazardous waste or hazardous waste constituents; is a chronic or recalcitrant violator; or deviates substantially from the terms of a permit, order, agreement or RCRA statutory or regulatory requirement. A facility is removed from SNC status when the facility returns to full physical compliance for all violations, and/or a facility is in compliance with a compliance schedule for any outstanding violations. If just one violation does not fall into one of the above categories, the facility is out of compliance and maintains its SNC status.

Closed Enforcement Actions: Closed administrative or civil judicial government actions that have been taken at a facility for violating environmental laws.

This indicator provides the number of closed federal and state/local enforcement actions that have been entered into federal data systems for each facility over the past two years. While the details and regulatory requirements differ across CAA, CWA and RCRA, an enforcement action can be defined as a formal action to address violations either administratively or through the court system. Only closed enforcement actions under CAA, CWA and RCRA are included. This information does not include notices of violation (NOVs), referrals and informal enforcement actions. More detailed information on the breakdown by each statute, the date, type of action, and penalty amount is available in the Detailed Facility Reports for each facility, accessible via the Data Access Page.

NOTE: The compliance history data within SFIP are limited to what EPA collects at the federal level. Thus, there may be enforcement actions at the state/local level that are not required to be reported to the federal systems.

NOTE: There are a number of other federal statutory requirements which are not included in the summary of enforcement actions for the facilities covered by this project. These include, for example, requirements under Superfund and the Safe Drinking Water Act.

Production or Production Capacity: Production or production capacity of a facility (e.g., tons/year).

SFIP includes information on the production or production capacity of SFIP facilities, except federal facilities. EPA prefers to use actual production; however, it is available only for the automobile assembly plants. Estimated average daily production is available for pulp manufacturers. For all other industry sectors, the production capacity for each facility is used. In all cases, this information is taken from published industry sources since production-related information is not currently collected nationally under any EPA program. Production or capacity of a facility is included as an indicator of facility size and complexity. Facility size is a useful indicator that provides more context to the chemical release and compliance information.

The following sources are used for each individual sector. Many of these sources collect information on a voluntary basis, and some companies choose not to report production capacity as a matter of corporate policy. EPA has offered each facility the opportunity to provide missing production or capacity information. Where such information was supplied and documented, it was incorporated into the current SFIP. For all sectors with multiple data sources, sources are listed in sequential order in which data were taken. Sources listed at the end were used to fill in data gaps when information was missing from primary sources.

SFIP matches the production data year to the year of frozen TRI data presented in the TRI Comparative spreadsheets.

• Automobile Assembly - Actual production. Units are number of passenger cars and light trucks produced. Source: Automotive News Market Data Book.
• Iron and Steel Production - Capacity.  Units are short tons of product per year (short ton = 2000 pounds). Sources: Association of Iron and Steel Engineers (AISE) Directory of Iron and Steel Plants; Steel Manufacturers Association (SMA) Membership Directory; Iron & Steelmaker Magazine's Electric Arc Furnace and Blast Furnace Roundups.
• Petroleum Refining - Operating and idle production capacity reported to the U.S. Department of Energy.  Units are barrels per day of atmospheric crude oil.  Source: U.S. Department of Energy Petroleum Supply Annual.
• Primary Nonferrous Metals Smelting and Refining - Capacity. Units are metric tons per year (metric ton = 2,200 pounds). Source: United States Geological Survey.
• Pulp Manufacturing - Actual average daily production. Units are short tons of product per day (short ton = 2,000 pounds). Source: Lockwood-Post's Directory of the Pulp, Paper and Allied Trades.

NOTE: The units of production and capacity differ across industry sectors and are relevant only for comparisons among facilities within a particular sector.

TRI Releases: Total pounds of TRI chemicals released to air, discharged directly to water, landfilled on-site or injected underground.

The primary source of chemical release data in SFIP is the EPA Toxics Release Inventory (TRI) program, which was established as part of the Emergency Planning and Community Right-to-Know Act. The TRI program was established to promote public awareness of chemical releases, but is not a "standard-setting" regulation that spells out chemical release limits. Under TRI, facilities meeting several criteria are required to self-report the amounts of certain chemicals released on-site, and transferred to other sites on a yearly basis. TRI maintains a listing of over 600 chemicals that must be reported. The regulatory limits for pollutant releases at these facilities are contained within individual single-media permits (e.g., Clean Air Act, Clean Water Act). Although chemical release information is an essential element of any facility or sector data profile, the reported releases may be allowed either because the chemical is not regulated, or is allowed under existing single-media permit limits. SFIP provides the total number of pounds released as reported by each facility. If the amount of a particular chemical released was given as a range of values (e.g. 500-1000 lbs.), the midpoint was used in the total. The TRI Website (click on the "Other Links" button ) provides total chemical release estimates and breaks down the on-site releases according to environmental media: air, land, underground injection, and water.

NOTE: Although TRI is considered the best and most comprehensive source of chemical release data, there are several limitations associated with this information. The user must recognize that self-reported releases may be submitted based upon estimation techniques rather than direct monitoring. Self-reported release amounts might not therefore represent the exact amount of release. Second, TRI is not a comprehensive listing of all chemicals released. Chemicals and chemical mixtures that may be released by facilities may not be on the list of reportable chemicals under the TRI program. Many of the single-media regulatory programs require data on these additional chemicals, and EPA is exploring ways to provide this information under SFIP.

NOTE: The user also should be aware that chemical releases at a given facility are not an indicator of whether the facility is in violation of environmental laws. Most of the chemicals reported under the TRI program may be allowable under existing single-media permits, or may be unregulated.

TRI Off-site Transfers: Total pounds of TRI chemicals either discharged to a sewer system or shipped off-site for disposal or treatment.

Off-site transfers of toxic chemicals from facilities meeting reporting thresholds are required to be reported to the Toxics Release Inventory (TRI). The off-site transfers reported to TRI are sent to a geographically or physically separate location for the purposes of recycling, energy recovery, treatment (including publicly-owned treatment works treating sewer discharges), or disposal. This indicator does not reflect actual releases following the management of chemical wastestreams off-site. The quantities reported represent a movement of the chemical away from the reporting facility. If the amount of a particular chemical released was given as a range of values (e.g. 500-1000 lbs.), the midpoint was used in the total. Because post-production management of toxics can occur either on-site or off-site, off-site transfers are an important complementary indicator to TRI chemical releases with which to characterize facility operations.

NOTE: The user also should be aware that chemical transfer amounts at a given facility are not an indicator of whether the facility is in violation of environmental laws. Most of the chemicals reported under the TRI program may be allowable under existing single-media permits, or may be unregulated.

Ratio of Chemicals Released and Transferred to Production or Capacity: Pounds of TRI chemicals released and transferred offsite divided by facility production or capacity (units differ by sector).

The ratio of TRI chemical releases and transfers to production or production capacity is designed to indicate differences in chemical releases per unit of production for facilities producing similar outputs. Because the unit of production or production capacity is specific to the industry sector or subsector, the unitless ratio is meaningful only within a given sector or subsector.  Note that the ratio of TRI chemical releases and transfers to production is not provided for federal facilities.

TRI Releases - Carcinogens: Pounds of known or suspect carcinogens released to the air or water, disposed of via underground injection, or landfilled on-site.

This indicator presents the pounds of known or suspect carcinogens released to the air or water, disposed of via underground injection, or landfilled on-site. If the amount of a particular carcinogen released was given as a range of values (e.g. 500-1000 lbs.), the midpoint was used in the total. Known carcinogens are those that have been shown to cause cancer in humans. Suspect carcinogens are those that have been shown to cause cancer in animals. A further description of these chemicals can be found in the TRI Public Data Release document available from EPA's EPCRA Hotline (800-535-0202). This indicator presents greater detail on chemical releases for a category of chemicals which may be of particular concern due to their possible effects on human health in the environment.

NOTE: This indicator includes releases of suspect or known carcinogens. It does not include off-site transfers.

TRI Releases and Transfers - Metals: Pounds of metals and metal compounds (only the metal portion of metal compounds) which were either released or transferred off-site.

This indicator presents the pounds of metals and metal compounds (only the metal portion of metal compounds) which were released or transferred off-site. If the amount of a particular metal released or transferred was given as a range of values (e.g. 500-1000 lbs.), the midpoint was used in the total. Metals differ from other TRI chemicals because they do not degrade and are not destroyed by treatment although they may be treated to reduce their availability to the environment. A further description of these chemicals can be found in the TRI Public Data Release document available from EPA's EPCRA Hotline (800-535-0202). This indicator presents greater detail on chemical releases and transfers for a category of chemicals which may be of particular concern due to their possible effects on human health and the environment.

NOTE: This indicator includes releases, as well as off-site transfers, of TRI chemicals. Reporting of TRI releases does not necessarily indicate that the chemical can readily migrate off-site. Off-site transfers are not necessarily managed near the facility.

TRI Production-Related Waste: Pounds of TRI chemicals contained in production-related waste prior to recycling, treatment, energy recovery or disposal.

Since 1993, in addition to releases and transfers, TRI reporting also includes estimates of TRI chemicals in waste from routine production during the calendar year. The amount reported as waste includes all waste flows prior to recycling (closed-loop/in-process recycling is excluded), treatment, energy recovery or disposal, whether management occurs on-site or off-site. This indicator is useful in characterizing existing source reduction efforts and in identifying further opportunities for source reduction.

NOTE: The user should be aware that production-related waste amounts at a given facility do not represent chemical releases or indicate whether the facility is in violation of environmental laws. Most of the chemicals reported under the TRI program may be allowable under existing single-media permits, or may be unregulated.

Pollutant Spills: On-site chemical or material spills within the past two years.

Pollutant spill information is included in SFIP as an indicator of disruptions to normal operations. Spill information is available from the Emergency Response Notification System (ERNS) database. SFIP Facility-level Statistics reports contain an indicator that shows whether any on-site spills occurring within the two years of data examined were identified for a given facility. An "ERNS Incident Report" is available for each facility with spills via the Data Access page of the SFIP Website. This report contains further details about each spill, such as: spill date, name of the material spilled, the quantity of the substance released, the number of injuries resulting from releases as reported, and the number of fatalities resulting from releases as reported.

ERNS stores information on releases of oil and other hazardous substances. Initial spill reports may be updated with information from various federal, state and local response authorities. The data are used for emergency planning efforts and in developing spill prevention programs. To link ERNS records with SFIP facilities, all ERNS records for spills occuring during the most recent two years that ERNS data has been available in the cities where SFIP facilities are located were reviewed. Spills were linked if there was a match between the address where the spill occurred and that of an SFIP facility. For this project, obvious duplicate and revised reports for the same events were eliminated by retaining only the "most-up-to-date" reports and by deleting spills reported for a particular facility with duplicate spill date and material spilled. For more information on the original source of pollutant spill data presented in SFIP, please access the National Response Center Homepage.

NOTE: ERNS is a "report-driven" database, containing mostly initial accounts made during or immediately after a release, when details are often unknown. While we have carefully screened the ERNS information included in SFIP, the data represented may not include all spills that have occurred at SFIP facilities.

Estimated Surrounding Population: Estimated population living within three miles of a facility and associated demographics.
SFIP includes a number of population-based statistics provided by the Bureau of Census. The total population within a three-mile 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. The Detailed Facility Report for each SFIP facility contains a wide variety of additional demographic and geographic information for the surrounding area, including but not limited to: percentage of households by income level; percentage of residents below poverty level; distribution of educational level in the population; race of residents; age distribution of residents; number of households; and percentage of area covered by water.

The calculation of surrounding populations was done using the latest TRI "preferred" latitude and longitudes, or as found in other EPA databases. Surrounding populations and other statistics were estimated by retrieving the data for 2000 Census block groups within three miles of each facility.

NOTE: Alternative methods (which may yield more accurate estimates), such as equal-area "weighted" population estimates and/or use of Census block data rather than block-group data, may be used in the future. In addition, the option to allow users to specify the radius may be included in future modifications of SFIP.

Estimated Surrounding Minority Population: The percentage of the population of the given area that is minority. The field is calculated by subtracting the number of persons who are white (and not of Hispanic origin) from the total persons. This number is then divided by the total persons and multiplied by one hundred to determine the percentage.

Estimated Percentage of Surrounding Population Living in Poverty: The percentage of people in the selected area that are below the poverty level.