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Data Collection/Data Entry Pilots
In 2001, EPA conducted several data collection/data entry pilots in EPA Regions 3 and 5. The primary purpose of these pilots was to identify which Institutional Control (IC) related information or data elements should be included in an IC tracking system, and to attempt to collect that universe of identified information at selected pilot locations.
During August 27 - 31, 2001, the first round of IC data collection pilots in EPA Region 5 were conducted. Teams visited Kent and Oakland Counties in Michigan and Marathon and Dane Counties in Wisconsin to gather legal instruments and information about IC enforcement, monitoring, and implementation costs at 23 sites. Building on their experiences in EPA Region 5, data collection teams visited York, Montgomery, and Chester Counties in Pennsylvania and New Castle and Kent Counties in Delaware from October 29 - November 9, 2001. IC information for 49 sites was collected in EPA Region 3.
During the pilot, the following data collection strategy was used:
- Phase 1
- Conduct desk-top review of available information; and
- Interview Remedial Project Managers (RPMs).
- Phase 2
- Interview appropriate state/local government officials; and
- Travel to relevant counties to interview appropriate officials and collect documents.
As a result of the data collection efforts in EPA Regions 3 and 5, the following general findings and lessons learned were identified:
Major Findings
- State/local ICs are not typically cited in the Record of Decision (ROD).
- Most construction completion sites had at least one IC implemented.
- There was no evidence of implementation for over half of the proprietary ICs required by EPA decision and/or enforcement documents.
Government ICs - State
- Locating state authorities on ICs is relatively simple and straightforward:
- All the state codes in the Regions 3 and 5 pilots were searchable on the Internet.
- Valuable guidance on locating state ICs is provided by RODs, particularly the section discussing applicable, or relevant and appropriate requirements (ARARs).
Government ICs - County
- Success in locating county authorities on ICs depends on the particular county:
- Three of the counties have the relevant regulations on the Internet.
- For the other counties, the teams had to rely on county officials.
- A number of the counties did not appear to have county-wide government IC authorities.
- The ARARs section of the RODs was a valuable source for locating many county ICs.
Government ICs - Other Local Jurisdictions
- The Region 5 pilot did not focus on local jurisdictions other than counties (e.g., township, boroughs, towns).
- In the Region 3 pilot, there was a strong focus on these other jurisdictions:
- In Pennsylvania, visits to township or borough offices resulted in a wealth of information on local zoning codes, comprehensive plans, ordinances, permit requirements, and land use regulations.
- In Delaware, where the focus was on the Wilmington and Dover city regulations, there did not appear to be authorities relevant for ICs; however, the regulations for both cities are available on the Internet for further consultation.
Proprietary ICs
- While the best source for locating proprietary ICs is the county Recorder of Deeds, these offices vary widely in their processes for accessing these documents. On different ends of the spectrum:
- Marathon County, Wisconsin maintains an electronic system that allows relatively easy searches by owner name and parcel number.
- Montgomery County, Pennsylvania has an antiquated system, which lacks a reliable index and where one has to request microfiches (that many times are not available) to see whether they contain relevant documents.
- In many cases, site address and site owner information from EPA databases lacked sufficient detail for locating the correct documents in the county Recorder of Deeds. In such cases, one had to contact relevant Mapping/Assessors/Treasurer/Township offices in an effort to identify properties.
Enforcement ICs
- The teams in both the Region 3 and 5 pilots encountered difficulty in locating all the relevant enforcement documents.
- Enforcement documents can be found in a variety of locations (e.g., county Recorder of Deeds, local Superfund Administrative Record Repositories); however, none of the locations appear to maintain a complete record.
- The teams contacted the Region 3 Superfund Administrative Record Repository in an effort to locate missing enforcement documents.
Following the development of EPA's Institutional Controls Tracking System (ICTS), the data collected during the EPA Regions 3 and 5 pilots were analyzed and entered into ICTS.
In May 2003, EPA Region 5 volunteered to participate in an IC data entry pilot. Regional staff, including RPMs, were trained on the data entry and data manipulation processes of ICTS. Following their training, EPA Region 5 entered information regarding ICs at the sites for which they are responsible. Through their hands-on experiences, EPA Region 5 has provided meaningful suggestions and comments for further improvements of ICTS and the national IC tracking network concept.