John’s helpful Key of codes & information found in AFS reports

1) Ignore the first cover page, that is just the criteria used to pull the data out of the system, so start on Page 2. 2) State Code ST = 06 simply means California. 3) CNTY (is the AFS County Code for Imperial County); which is the ONLY data in this report 4) Next 5 digit number beginning with “I” indicates a facility is an Imperial source (in Imperial County & the numbers following the I often relate to a permit ID# in some way) 5) Next you’ll see a line wi th the facility’s name, address, any air programs the facility is known to be subject to (v = Title V, o = SIP, 6 = PSD, 7=NSR, 8= NESHAPS, 9 = NSPS, & M = Mact for example), next is an operating status O = operating & is most common; X = permanently shut down. There is next a SIC Code, which is a government standard code describing what sort of business this is (eg what they make); class size A means the plant is major source (normally capable of emitting something > 100 TPY in a more rural part of CA), but most all majors have controls so they’re not normally emitting that amount ( FYI

- a different database tracks emissions data) ; Compliance status of 3 means currently “In Compliance” (eg not emitting beyond allowed limits); 9 means shut down (part of a ll of the plant) 1 means in violation (usually because of an HPV) (while B means in violation procedurally & for emissions; while W means in violation only procedurally). Compliance status is the least accurate code in AFS & is one reason we’re hoping to modernize, sometimes these codes are old or Obsolete & when we modernize they’ll be automated to be FAR more accurate. 6) Last on first line is the year of emissions inventory (this information is also obsolete, but isn’t removable from this report, just igno re. 7) Here is where the actual data begins. You will see an action number (a sort of record number), then an action type code for what was done, and it’s followed by a description of what was done. So RD is an older (now obsolete) term for an inspection an d it says District Level 2 (the old term for conducting an inspection of the whole plant). Nowdays those are known as RY (Full Compliance Evaluation) but mean the same thing & you will see some here. RV means they only saw PART of the plant (perhaps 1 bo iler or 1 coating line or something like that for some specific reason). Next you’ll see a date in YYMMDD format (this is the date the inspection or other action occurred). So the first inspection was 981028 or was conducted 10

- 28

- 19 98

, or October 28, 19 98 . The last code is a result & 25 means “compliance” (24 means some violation was found and 23 means unknown). More modern result codes include MC = Compliance, MV = violation, and MU = unknown; while for tests the values are PP = Pass & FF = Fail. Ti tle V certifications with MV and Tests with FF do not ALWAYS mean something was serious enough to be an HPV (reportable violation) so if one of those doesn’t fall within a sequence where there is a KEY # (normally these HPVs with Keys are at the end of the list for each plant, so they’re easier to see, and only those were subjected to reporting to us as getting some enforcement worthy of federal interest in our database. So thismeans any other MV or FF codes are really covering very small stuff & were ins tead

handled locally. 8) So on some other plants you will see Action types like RZ (District Source Test) which means the district (Imperial) conducted a source test of some emissions unit. While there’s also a code for RT, source test (conducted by a testi ng firm normally) and which was reviewed by the local district (Imperial). 9) RS

– Title V certification reviewed by local means the facility submitted a self

certification (required under Title V program) and district reviewed it. Anything other than 100% p erfect performance for the whole year reviewed gets coded MV, so that’s sometimes a bit misleading. Only the really BIG stuff here for these would qualify as an HPV, so most other stuff (again anything not linked to an HPV) was usually something

small or fixed by the time of the reporting to district. 10) Where you see a KEY number, those are the HPVs (eg reportable enforcement). A typical HPV has 5 steps linked together. If you see repeats in the Key or in the action number, those are usually due to what th is report does when it has a comment (far right) with more than 1 line, so any long comment will cause repeats, just ignore that). Here’s a sample of 4 lines of an HPV, with one repeated Day Zero line due to the

comment:

00030 30 S9 DIST DAY 0 040815 24 N OV# 3233;VIOLATED PTO CONDITIONS;$1000;DIST WITNESS TESTING 00030 30 S9 DIST DAY 0 040815 24 PENALTY ALSO INCLUDES FIXING EQUIPMENT.

00030 31 S8 DIST NOV 040815 24

00030 34 SP LOCAL LET ORDER 041022 24

00030 36 SO DIST SV RESOLV 041111 25

So here we see for Key (HPV) 00030, it begins with the Day Zero (8/15/ 2004 ) and repeats because of the longer comment, then there’s the NOV (Violation Notice issued) telling facility they were in violation (same day) and a couple of months later an Administrative Letter offering settlement was sent from District’s legal to facility (on 10/22/2004) and finally by 11/11/2004 the facility had paid up (presumably problem was fixed long before). The comment tells us this was NOV# 3233 for violating permit conditions about dus t found during testing & some sort of repair to the facility’s equipment was also needed before district would say it was ok. Facility was required to pay $1,000 for this violation & did pay up & fix it. And all this happened within about 3 months; so th is was a very quick settlement.

In SOME HPVs you may also see an additional action describing how the violation was found (like maybe linking in an inspection or something like that). So that is how to read a violation history from this data

– now you’re an EXPERT!

Sometimes the comments repeat, that is unfortunate, but just one of the other reasons we can’t wait to get ‘modernized’ at last after 30+ years with this database.

Feel free to call me (415) 972

- 3985 if you have any other questions about this data. John Borton