RCRAInfo Data Quality Plan & Processes

1. RCRAInfo Data Quality Plan & Processes 2005 RCRAInfo National Users Conference August 2 – 5, 2005 Nashville, TN

2. Overview • OECA Data Quality Audits • V3 Conversion CM&E Data Quality Reports • V3 CM&E Data Quality Reports • Internal CM&E DQ Reports Which OECA Runs Monthly • EPA’s Information Quality Guidelines • RCRAInfo Data Quality Plan • Comments & Discussion

3. OECA Data Quality Audits • Two data quality audits • Evaluation • Enforcement • Data Systems • RCRAInfo • Permit Compliance System (PCS) • Air Facility System (AFS) • Integrated Compliance Information System (ICIS) • Random sample of TSDF & LQG sites chosen • Almost 100% participation!

4. OECA Data Quality Audits(cont.) • RCRAInfo Evaluation Data Audit • Data verified against paper inspection reports • Accurate 98% of the time (+/- 2%) • RCRAInfo Enforcement Data Audit • Data compared against actual enforcement orders • Accurate 97% of the time (+/- 2%) • RCRAInfo scored highest of all systems evaluated!

5. V3 Conversion CM&E Data Quality Reports • Available on RCRAInfo partnership web • These are spreadsheet images (not run real-time) • Current • Compliance Assistance Visit (CAV) Evaluations Having Linked Violations • Penalty Records with Zero Amount • Orphan Enforcement Actions Conversion Report • Soon • Orphan Violations • How to find: RCRAInfo Main Menu, News Alerts & General Information, RCRAInfo News, Version 3 Documentation • Available in RCRAInfo V2 • CM&E Orphan Enforcement Actions Report • Run directly by user

6. V3 Conversion CM&E Data Quality Reports (cont.) • Compliance Assistance Visit (CAV) Evaluations Having Linked Violations • CAVs not allowed to identify violations • Violations will be deleted

7. V3 Conversion CM&E Data Quality Reports (cont.) • Penalty Records with Zero Amount • Payment records created not linked to penalties • Payments will be deleted upon conversion

8. V3 Conversion CM&E Data Quality Reports (cont.) • Orphan Enforcement Actions Conversion Report • Identifies orphaned enforcement actions created in conversion by deleting implementer-specific violations

9. V3 Conversion CM&E Data Quality Reports (cont.) • Orphan Enforcement Report • Identifies orphaned violations that will be deleted in the final conversion • Available soon • CM&E Orphan Enforcement Action Report • Current national standard report • Direct link found on RCRAInfo national implementer CM&E Reports Menu • Developed by Region 6

10. V3 Conversion CM&E Data Quality Reports (cont.) • CM&E Orphan Enforcement Action Report

11. V3 Conversion CM&E Data Quality Reports (cont.) • CM&E Orphan Enforcement Action Report (cont.) • Review to identify & correct enforcement actions which should be linked to violations. • With V3 all enforcement types will be required to be linked to at least ONE violation EXCEPT: • Section 3008(h) Imminent and Substantial Endangerment • Section 3013

12. V3 CM&E Data Quality Reports • Six new data quality reports will be available on the national implementer CM&E reports menu • QA/QC Commitment/Initiative Data • QA/QC SNY/SNN Evaluations Not Linked to Violations • QA/QC Information Request Data • QA/QC RCRA Section 6002 Data • QA/QC SNCs With Open Technical Requirements • QA/QC of Open SEPs

13. V3 CM&E Data Quality Reports (cont.) • QA/QC Commitment/Initiative Data Purpose: • List commitments not linked to evaluation • Review progress towards the accomplishment of commitments • QA/QC of SNY/SNN Evaluations Not Linked to Violations Purpose: • Review SNY and/or SNN evaluations not linked to violations • Note: Linking violations to SNY/SNN evaluations is optional.

14. V3 CM&E Data Quality Reports (cont.) • QA/QC Information Request Data Purpose: • List information requests not linked to evaluation • Review open information requests • QA/QC RCRA Section 6002 Data Purpose: • Review EPA-conducted evaluations at federal facilities

15. V3 CM&E Data Quality Reports (cont.) • QA/QC SNCs With Open Technical Requirements Purpose: • Review sites that have been unclassified as a SNC but have remaining open technical requirements • QA/QC of Open SEPs Purpose: • Review open supplemental environmental projects that are coming due or are past due.

16. Internal CM&E DQ Reports Which OECA Runs Monthly • Evaluation • Count of Evaluations by Region, State, and Agency • SNY or SNN with Agency Other Than E or S • Found Violation = N and Violations Linked • Found Violation = Y and No Violations Linked Except CAV (Compliance Assistance Visit) • Evaluation FCI (Focused Compliance Inspection) Without Focus Area Linked • Focus Area Entered Without FCI Linked Evaluation • Evaluations Without Day Zero Entered • EPA Evaluation Conducted at Federal Facilities Without Linked C6002

17. Internal CM&E DQ Reports Which OECA Runs Monthly (cont.) • Violation • Count of Violations by Region, State, and Agency • EPA Violation Without Linked Citations • Orphaned Violations • Orphaned Citations • Enforcement • Count of Enforcement Actions by Region, State, and Agency • Orphaned Media • Orphaned CAFOs (Consent Agreement/Final Order) • Orphaned Penalties • Orphaned Payments • Orphaned Milestones

18. EPA’s Information Quality Guidelines • The Issue • Need to improve data quality & reduce errors, especially on data that EPA makes available to the public & stakeholders. • In the past, EPA had no way to ensure that reported errors were fixed after a notification was received on a data quality complaint.

19. EPA’s Information Quality Guidelines (cont.) • The Solution • EPA’s Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency developed to comply with OMB guideline (67 FR 8451, February 22, 2002) • www.epa.gov/quality/informationguidelines/index.html • Created Integrated Error Correction Process mechanism which enables public to report & obtain correction (if appropriate) of information disseminated by EPA that does not comply with EPA or OMB Information Quality Guidelines.

20. EPA’s Information Quality Guidelines (cont.) • Highlights of Impacts on RCRA Information Managers • RCRA Biennial Report data • CM&E data • Inspector General Audits

21. RCRAInfo Data Quality Plan • Background • A preliminary RCRAInfo National Data Quality Plan was developed in 2002 which needs to be finalized • It consists of the following sections: • Introduction • Quality Goals & National Priorities • Roles and Responsibilities • System-based Quality Controls • Quality Validation Processes

22. RCRAInfo Data Quality Plan (cont.) • Introduction • Plan defines national framework for RCRAInfo data quality • Applicable to national, mandatory data only

23. RCRAInfo Data Quality Plan (cont.) • Quality Goals & National Priorities • When information relating to mandatory elements is received or program activity occurs, corresponding values should be reflected in RCRAInfo. • Timeliness • Central Data Exchange (CDX) submissions by RCRA sites should be reviewed and action taken within not more than one week ofthe time the signed transaction certificate is received.

24. RCRAInfo Data Quality Plan (cont.) • Quality Goals & National Priorities • Timeliness (cont.) • For States & Regions using RCRAInfo direct data entry, updates should occur not more than one week from the time information is received from the RCRA site or program activity occurs. • Translators must submit national data to RCRAInfo at least once a month. • Updates in implementer’s system should occur not more than one week from the time the information is received from the RCRA site or program activity occurs to ensure that it is processed in the monthly update (5-week period max)

25. RCRAInfo Data Quality Plan (cont.) • Quality Goals & National Priorities • Accuracy • RCRAInfo data should properly reflect information received from a site or as identified via program activity. • Potential errors submitted via EPA’s error correction process should be assessed, a determination made, and any related data updates made within not more than six weeks.

26. RCRAInfo Data Quality Plan (cont.) • Quality Goals & National Priorities • Most critical for national program management are those elements needed for reporting under Government Performance Results Act (GPRA) • Permitting/Closure/Post-Closure • Compliance Monitoring & Enforcement • Corrective Action

27. RCRAInfo Data Quality Plan (cont.) • Roles and Responsibilities • National Program Managers • OSW • Establishes national priorities for program information & quality via RCRAInfo Change Management Process. • Coordinates program & information quality reviews with program implementers. • OECA • Defines national priorities for program information & quality • Participate as partner in RCRAInfo Change Management Process.

28. RCRAInfo Data Quality Plan (cont.) • Roles and Responsibilities (cont.) • Region/State Program Implementers and Managers • Ensure RCRAInfo promptly & accurately reflects accomplishments & key program/environmental status conditions • Respond promptly to requests for resolution of potential errors identified via EPA’s error correction process • Regulated Community • Supply information mandated by regulatory reporting requirements accurately & promptly

29. RCRAInfo Data Quality Plan (cont.) • Roles and Responsibilities (cont.) • RCRAInfo System & Database Managers • Implementer • Routine system administrative duties • User access management • Maintaining implementer-defined lookup table values • Run & review data quality reports • Work with program management regarding QA

30. RCRAInfo Data Quality Plan (cont.) • Roles and Responsibilities (cont.) • RCRAInfo System & Database Managers • Implementer • Routine system administrative duties • User access management • Maintaining implementer-defined lookup table values • Run & review data quality reports • Work with program management regarding QA

31. RCRAInfo Data Quality Plan (cont.) • Roles and Responsibilities (cont.) • RCRAInfo System & Database Managers • National • OSW Information Management Branch (IMB) • RCRAInfo development, operations, & support • Managing database to ensure data integrity at application level (processing translator loads, generating data exports for Agency & public use • National data quality review with Regions & States for each Biennial Report cycle • Together with Analysis & Information Branch (AIB) in OSW, provide operational & logistical support for Change Management process

32. RCRAInfo Data Quality Plan (cont.) • System-based Quality Controls • Structural & Security Measures • Access password protected via named user over secure channels • Application enforces access levels & IOR • Each RCRAInfo record includes user id & timestamp for last update to support resolution of data discrepancies

33. RCRAInfo Data Quality Plan (cont.) • System-based Quality Controls (cont.) • On-line Processing Controls • Element level • Use of look-up tables and pick lists where possible • Transaction Integrity • Data for all mandatory elements must be supplied or record will not be saved to database • Transaction controls defined via national design & development process which addresses changes defined through RCRAInfo Change Management Process

34. RCRAInfo Data Quality Plan (cont.) • System-based Quality Controls (cont.) • On-line Processing Controls (cont.) • Application-based Edit Checks • Ex: CM&E Module: Verify that determined data of violation is not before data of evaluation, & that date of enforcement action is not before the data the violation it addresses was determined • Prevent orphans from being created • Validation of Files Received from External Systems • Translator files subject to mandatory element & transaction level controls

35. RCRAInfo Data Quality Plan (cont.) • System-based Quality Controls (cont.) • On-line Processing Controls (cont.) • Data Quality Reporting • RCRAInfo provides data assessment reports which facilitate data validation reviews

36. RCRAInfo Data Quality Plan (cont.) • Quality Validation Processes • This section summarizes QA/QC processes & highlights their importance.

37. RCRAInfo Data Quality Plan & Processes Questions? Comments?

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