State Comments on Frozen Data - 2009

State comments on frozen data are available through the links below, organized by the submission year. Additional data quality information which is not specific to the frozen data is available through the known data problems and State Review Framework Recommendations Tracker.

2009 Comments on Frozen Data (Captured April 2010)
State Media Comments Data Links
Alabama CAA For the CAA data, the SRF data metrics erroneously assume that any source classified as a major source at the plant level should be identified as a major source subject to the CMS policy and should have a Title V air program code. However, due to the State of Alabama's continued regulation of total suspended particulates (TSP), the State has numerous sources that are major sources under the PSD air program due to their potential to emit TSP. In AFS, Alabama has correctly entered these sources without a Title V air program code and as not being subject to the CMS policy. In addition for its CAA data, the State of Alabama submits a monthly update to AFS which reflects each source's current status and classification under each air program. Therefore, Alabama has decided that it is not a wise use of its resources to undo these changes so that all sources' status and classification under each air program will reflect its historical status during FY2009 for EPA's 2009 data freeze. Since Alabama only updates its CMS universe annually, the CMS universe at the time of the data freeze is correct for FY2009. As a result of these factors, there may not be 100% agreement between the CMS universe and the CAA major and synthetic minor universe for the 2009 SRF frozen data.  
CWA The state has identified a number of significant discrepancies between its own internal data and EPA's data relating to compliance monitoring and enforcement activities. Because EPA does not currently except external data flows of this information from the state, the data metrics do not accurately reflect the activities performed by the state. EPA and the state are working as closely and as quickly as possible to address this issue.  
RCRA Metric 3A: A problem exists with multiple entries and data from outside the FY 2009 timeframe being pulled by the SRF data logic.

Metric 10A: A problem exists with a SNC not being counted as having formal enforcement within 360 days when the 360 day timeframe has not expired.

In many instances, SRF data does not match data compiled using other RCRAInfo reporting tools, but the variance is usually less than 10%.
 
Alaska CAA Alaska is verifying the subparts for the various air programs codes for sources for correctness, therefore the data metrics do not reflect the complete number of activities performed by the state.  
Arkansas CWA   Data Link (PDF) (12 pp, 63K)
Connecticut CWA Connecticut has requested that EPA change the MAJOR/MINOR rating of 5 NPDES permits, but this has not yet been completed by EPA. These changes will affect many of the data metrics as they are based on the total number of major or non-major permits.  
Delaware CAA   CAA Data Alert
Data Link (PDF) (51pp, 80 K)
CWA   Data Link (PDF) (1pp, 46 K)
District of Columbia CAA 1) Washington Metropolitan Area Transit Authority (WMATA) - 11/001/09001 - Should have a Title V air program code (V).

2) Not all area source MACT facilities have appropriate subparts, most notably perchloroethylene dry cleaner facilities which should have MACT subpart M associated with them.

3) Senate Asphalt (11/001/00002) is a permanently closed facility and should therefore not be listed as being in violation.

4) Howard University (11/001/00022) has duplicate formal enforcement actions on 9/18/09. Only one was issued.
 
Florida CAA Three data issues remain for the state's data: 1) The state reports violations according to EPA's HPV Policy and expects to report other non-HPV violations upon EPA's issuance of their guidance for Federally Reportable Violations. 2) The state has approximately 75% of it's air program subpart data reported to date, and expects completion of this data soon. 3) The EPA Region 4 has lead enforcement for CFC sources in Florida, and has been working on correcting the historical non compliance status codes for these sources in their national database. Florida's compliance and enforcement data can be viewed on its AirInfo Data Search.  
RCRA A problem with data translation of compliance and enforcement actions still exists, so the data metrics do not correctly reflect amounts for RCRA enforcement penalties assessed by the state (12.b), violations returned to compliance within 240 days (2.b), and numbers of SNC with formal enforcement action/referrals taken within 360 days (10.a).  
Idaho CWA Values displayed on the Framework Results report for the following metrics appear accurate as they reflect the data reported into ICIS and the supporting documentation received for data entry: 1F1, 1F3, 1F4, 1G1, 1G2, 5B1, and 5B2.

Values displayed on the Framework Results report for the following metrics are not accurate: 1F2, 1G3, 1G5, 5A, and 5C. See below for corrected counts and explanations.

1F2 - Formal actions: number of actions at major facilities (1 FY): 2 3
The metric results count for 1F2 does not accurately reflect the number of actions reported into ICIS. The correct count is 3. One of the majors, ID0000175 - Hecla Mining, had 2 actions (10-2009-0015 and 10-2009-0143).

1G3 - Penalties: total collected pursuant to civil judicial actions (3 FY): $185,000 $75,000
The metric results $ value for 1G3 does not accurately reflect the data reported into ICIS. The Total Penalty Collected for 10-2006-0379 - Tamarack Resort LLC is $75,000; the Total Federal Penalty Required is $185,000. This facility is bankrupt and has only paid $75,000.

1G5 - No activity indicator - total number of penalties (1 FY): $578,492 $86,000 The metric results $ value for 1G5 (penalty no activity indicator) does not accurately reflect the data reported into ICIS. The correct $ value is $86,000. The only case with no penalty activity is 10-2009-0041, and the Respondent in this case is on a payment schedule to pay the full $86,000 penalty within 3 years from the effective date of the final order.

The cases listed below should be removed from the Framework Results report for metric 1G5 for the reasons indicated below:
The Total Penalty Collected $ values indicated for the cases listed below already exist in ICIS (ICIS data is accurate):
10-2009-0015 - $85,000 (paid in full)
10-2009-0046 - $5,450 (paid in full)
10-2009-0005 - $6,942 (paid in full)
10-2009-0010 - $14,900 (paid in full)
10-2009-0020 - $1,300 (paid in full)
10-2009-0231 - $13,100 (paid in full)
10-2009-0022 - $7,200 (paid in full)
10-2009-0007 - $12,500 (paid in full)
10-2009-0053 - $7,450 (paid in full)
10-2009-0024 - $2,600 (paid in full)
10-2009-0014 - $7,250 (paid in full)
10-2009-0001 - $10,000 (partial payment; the total Federal Penalty Required is $47,700)
10-2009-0234 - $2,150 (paid in full)
10-2009-0021 - $7,750 (paid in full)
10-2009-0187 - $50,000 (paid in full)

The Total Penalty Collected $ values indicated for the cases listed below were reported into ICIS on 3/18/2010:
10-2008-0149 - $2,000 (partial payment; the total Federal Penalty Required is $12,900)
10-2009-0029 - $11,000 (paid in full)
10-2009-0052 - $5,800 (paid in full)
10-2009-0143 - $177,500 (paid in full)
10-2009-0172 - $14,000 (paid in full)

5A - Inspection coverage: NPDES majors (1 FY): State 12, EPA 12 13, Combined 23 24
The metric results count for 5A does not accurately reflect the number of NPDES majors inspected by EPA. The correct EPA count is 13. A EPA NEIC multimedia inspection (for ID0001163 - Clearwater Paper Corporation) was reported into ICIS on 3/11/2010 (late ICIS data entry due to late inspection report submittal). It's noted that for purposes of this matrix, ID0022055 - Lewiston received 2 inspections (1 EPA and 1 State), however for NPDES majors coverage it's only counted once. In addition, the 2 SSO inspections by EPA (ID0020168 - Jerome, and ID0021784 - Pocatello) are included in this count because they have NPDES Individual Permits which address more than SSOs (not solely SSO permits).

5C - Inspection coverage (not 5A or 5B): State 0, EPA 10? (needs further review, this # may change to 31 or 34), Combined 10?
The metric results for 5C may not accurately reflect the total number of NPDES facilities inspected due to a possible data quality issue (inaccurate Permit Status due to missing ICIS data). The metric drilldown list of 10 facilities includes 8 NPDES minor CAFO General Permit Covered Facilities (all have an IDG01 #); 1 NPDES major with a Stormwater MS4 Individual Permit (IDS027561); and 1 NPDES minor Stormwater General Permit Covered Facility (IDR10B355). [This metric includes only those facilities with a Permit Status of Effective or Administratively Continued , and have Permits which address solely Stormwater, Pretreatment, CAFOs, CSOs, or SSOs.]

In my review of ICIS data, I noted that the following list of 24 Stormwater General Permit Covered Facilities were inspected in FY 2009, however they were excluded from the metric count for 5C because of their Expired or Pending Permit Status in ICIS. The Permit Status reflected in ICIS appears to be inaccurate due to missing Permit data (out-of-date or missing Permit Effective/Expiration Dates). With this message, I'm referring this data issue to Diane Davis for further review and any needed ICIS data correction.

Permit Status in ICIS: Expired (3 facilities with expired Permits)
IDR05A351, IDR10AX09, IDR10AX10

Permit Status in ICIS: Pending (21 facilities with missing Permit Effective/Expiration Dates)
IDR05C050, IDR05C177, IDR05C215, IDR05C429, IDR10BC48, IDR10BF77, IDR10BI96, IDR10BJ89, IDR10BN46, IDR10BU60, IDR10BW67, IDR10BX99, IDR10BY01, IDR10BY67, IDR10BZ79, IDR10C102, IDR10C103, IDR10C107, IDR10C108 IDR10C176, IDR10C266
Data Link (PDF) (1pp, 6 K)
Illinois CWA The number of NPDES non-major individual and general permits may be higher than indicated due to recent unprocessed permit renewal activities in Illinois.  
Indiana CAA Problems with the translation of data between EPA and the State of Indiana exists for inspection data, so the data metrics possibly do not reflect the complete number of activities performed by the State. Data Link (PDF) (2pp, 13 K)
RCRA Counts for LQG and SQG Inspections

The counts in data metric 1, the number of inspections at LQGs and SQGs uses the currently active universe of generators. The generator universe changes on a daily basis. At the beginning of each fiscal year Indiana commits to do a certain number of inspections at LQGs and SQGs. We conduct all those inspections. After we conduct the inspections facilities often change their generator status. Therefore Indiana will inspect a facility that was an LQG at the time it was picked, but later changes to SQG. The SRF measures look at the inspections at facilities that are CURRENTLY within a certain generator status. Therefore these figures are not correct. Indiana has in fact done more inspections than is reflected.

Non-RCRA Activities

In addition to inspections at facilities that have notified for RCRA activities, Indiana conducts many inspections at facilities that have not notified, but conduct activities that may be of concern. These inspections, violations, informal, formal actions, and penalties are NOT reflected in the State Review Framework numbers.

Inspection Coverage at TSDFs

There is one state owned facility that IDEM is not required to inspect; all other TSDs received an inspection in the required time frame.
Data Link (PDF) (1pp, 8 K)
Kansas CWA States are not required to enter data into PCS for non-majors. Kansas has its own wastewater database system for tracking all Kansas-permitted wastewater treatment systems. Therefore, the data for any metric associated with non-majors in Kansas is not accurate.

Kansas is not approved to run the pretreatment program. Therefore, data entry for metrics associated with the pretreatment program in Kansas are the responsibility of EPA.

EPA loads the Kansas enforcement data to PCS. However, many non-major facilities on which Kansas has taken enforcement action are not NPDES facilities and therefore, the enforcement data can not be loaded into PCS. Therefore, the enforcement matrix data set for non-majors in Kansas is not complete.

Kansas uses both schedules of compliance and formal enforcement actions to bring facilities back into compliance. EPA does not recognize schedules of compliance as formal enforcement actions (FEAs) although the requirements for issuing of and compliance with each are the same. Therefore, the number and percentage of "Major facilities without timely action" is distorted by EPA not recognizing schedules of compliance as satisfying this matrix requirement.

Finally, most of the facilities claimed to be in Significant Non-Compliance are the result of the errors in programming requirements to PCS and failure of the State to timely load Discharge Monitoring Report data into PCS rather than actual permit limit violations.
 
Kentucky CAA Because of discrepancies between the frozen data in the EPA's FY 09 report and the current data in Kentucky's database, it is suggested that any questions be forwarded to the Kentucky Division for Air Quality, (502) 564-3999, Extension 4453, or Jon.Trout@ky.gov.  
CWA A data entry problem was discovered with the penalty collected data for Kentucky. A portion of the penalty collected data is incorrect.  
RCRA Metric 5c: The SRF metrics list 3 Large Quantity Generators (LQGs) as not having been inspected in the last 5 years. RCRAInfo show that two of these three facilities were inspected within the last 5 years.

Metric 5d: The SRF metrics show 73 Small Quantity Generators (SQGs) as not having been inspected within the last 5 years. RCRAInfo shows 15 of these facilities as having been inspected within the last 5 years. There are 11 SQGs that registered within the last year, and 20 Wal-Marts that modified their generator status to SQGs on 12/10/09. There were 8 facilities located along natural gas pipelines that are episodic generators and only generate waste when the lines are cleaned. Most of the 8 pipeline sites did not generate waste during the previous 5-year period. There are 25 SQGs (7%) that actively generated waste within the past 5 years that were not inspected.
 
Maine RCRA Data issues remain for the RCRA data, and the state has posted general information about EPA's ECHO (OTIS) data at the following URL http://www.state.me.us/dep/enforcement/echo.html. More specifically, data issues remain for the following reasons or areas, or under the following caveats:

1. Maine conducted inspections at LQGs that are part of the RCRAInfo LQG Universe, but these LQGs do not show up in the Biennial Report LQG universe. Because EPA calculates inspection coverage by using the Biennial Report LQG universe, Maine's inspection coverage is not fully captured by EPA's metric [EPA metric 5.B.0 = Inspection coverage for LQGs (1 FY)]. EPA's metric indicates 10.9% coverage of LQG Universe, but the actual coverage is a higher percentage of the LQG Universe.

2. The data issue identified in item #1 above also occurs for EPA metric 5.C.0 [Inspection coverage for LQGs (5 FYs)]. Again, during the five year review period, Maine's inspection coverage for LQGs included LQGs that are part of the RCRAInfo LQG Universe, but which do not show up in the Biennial Report LQG universe. As a result, EPA's metric for inspection coverage for five fiscal year review period understates Maine's inspection coverage for LQGs.

3. Maine conducts inspections at facilities that do not have EPA ID#s and are not required to notify EPA or Maine of their hazardous waste activities (i.e. Small Quantity Generators and other non-notifier facilities identified through citizen complaints). The inspections activities, enforcement actions, and resulting monetary penalties assessed or collected as a result of such enforcement activities by Maine are not captured or reflected in the EPA metrics. As a result, EPA's metrics understate Maine's full range of hazardous waste compliance, inspection, and enforcement efforts.
 
 
Michigan RCRA   Data Link (PDF) (1pp, 4 K)
Mississippi CWA Metric 1.b.3 - NPDES Major individual permits: DMR entry rate based on DMRs expected (Permits/Permits) (1 Qtr- 7/1/09 to 9/30/09). This data represents the Major NPDES facilities that had a DMR present in PCS for the last quarter of FY09. After review of the metric data, the State has determined that 91 Major facilities should be counted as having DMRs present in PCS for the period 7/1/09 through 9/30/09, instead of the 82 that are listed on the SRF/ECHO report. The SRF/ECHO report does not include DMR's for Major facilities whose permits were re-issued after 9/30/09. The SRF/ECHO software does not look for, or pull, data related to expired permits. The State believes that DMR's submitted prior to 9/30/09 by facilities whose permits were re-issued after that date should be included in the count for this metric. Based on the number of facilities that have DMRs present in PCS, the submittal percentage for Majors would be 91/91, or 100%.

Metric 1.c.3 - Non-major NPDES individual permits: DMR entry rate based on DMRs expected (Permits/Permits) (1 Qtr - 7/1/09 to 9/30/09) This data represents the non-Major NPDES facilities that had a DMR present in PCS for the last quarter of FY09. After review of the metric data, the State has determined that 1,294 Non-Major facilities should be counted as having DMRs present in PCS for the period 7/1/09 through 9/30/09, instead of the 317 that are listed on the SRF/ECHO report. The SRF/ECHO report does not include Non-Major facilities whose permits were re-issued after 9/30/09, or Non-Majors that only have a yearly DMR submittal requirement. The SRF/ECHO software does not look for, or pull, data related to expired permits. The State believes that DMR's submitted prior to 9/30/09 by facilities whose permits were re-issued after that date should be included in the count for this metric. Furthermore, the SRF/ECHO report does not include DMR's that were submitted outside a window of time between 8/2/09 and 11/1/09. The logic excludes the State's Non-Major NPDES facilities whose DMR submittals are required to be submitted only on an annual basis and whose deadline for submittal fell outside of the August to November time frame Based on the number of facilities that have DMRs present in PCS, the submittal percentage for Non-Majors would be 1294/1438, or 90.0%.

Metric 5.b.1 - Inspection coverage: NPDES non-major individual permits (1 FY) This data represents the non-Major NPDES facilities that had an inspection completed for FY09. The SRF/ECHO logic does not include inspections that were performed at Non-Major NPDES facilities that are now Inactive. Based on the number of facilities that have had inspections for FY09, the inspection coverage should be 152/1438, or 10.6%.

Metric 5.b.2 - Inspection coverage: NPDES non-major general permits (1 FY) This data represents the non-Major general permit facilities that had an inspection completed for FY09. The SRF/ECHO logic does not include inspections that were performed at Non-Major general permit facilities that are now Inactive. Based on the number of facilities that have had inspections for FY09, the inspection coverage should be 104/1199, or 8.7%.

Metric 1.c.1 - Non-major individual permits: correctly coded limits (Current) This data represents the non-Major NPDES permits that SRF/ECHO considers as coded incorrectly (190 permits). Of the 190 permits listed as coded incorrectly, 19 are permits that are coded in PCS as "Applications Received Only." When an application for an NPDES permit is received, the State establishes that facility in PCS in accordance with instructions from EPA. Because no limits have been established for that facility at the time of entry, the limits are coded as "Application Received Only." Furthermore, there are 58 are permits that are coded in PCS as not having any outfalls/limits. Those facilities, while being subject to NPDES regulation, have no discharge limits, and are coded into PCS as such due to Standard operating procedures for the State. The State considers these 77 permits to be coded correctly, and the measurement should be 1325/1438 or 92.1%
 
RCRA Metric 1.a Number of LQGs per latest official Biennial Report: This data represents a 2007 LQG universe and has changed significantly since the last official biennial report. Because this universe is not an accurate representation of LQGs for FY 2009 it should not be used as the denominator for 2009 inspections in Metric 5.b and 5.c.

Metric 5.b: This metric uses the number of LQGs per the latest official Biennial Report (2007). The number of active LQGs in RCRAInfo is a more up-to-date and thus more accurate representation of MS's LQG universe as of September 30, 2009 and should be the denominator used for this metric. Based on the number of active LQGs in RCRAInfo for 2009, inspection coverage percentage would be 51/179, or 28.5%.

Metric 5.c: This metric uses the number of LQGs per the latest official Biennial Report (2007). The number of active LQGs in RCRAInfo is a more up-to-date and thus more accurate representation of MS's LQG universe as of September 30, 2009 and should be the denominator used for this metric. Based on the number of active LQGs in RCRAInfo for 2009, inspection coverage percentage would be 158/179, or 88.3%.
 
 
Nebraska CWA Inspection for storm water, General Permits, Compliance Assistance, and Complete Retention lagoons do not appear in the data because they cannot be associated with an NPDES number in ICIS.  
RCRA 1) Clean Harbors is an operating TSDF; the total # of operating TSDFs should be 4 not 3. I also compared the total # of compliance monitoring inspections and there were a total of 40 in OTIS; however, the total number should be 42 - as there were 2 Clean Harbors inspections conducted (NED981723513) CEI dates: 9/29/09 and 6/9/09. Also, Clean Harbors does not show up on the report for total # of sites, with violations determined, etc.

2) The end of the review period FY09 list of LQGs appeared to be slightly off. Using RCRARep I show 63 LQGs, compared to 66 in OTIS, SQGs 391, compared to OTIS 392, and CESQGs 1213 compared to 1151 in OTIS.

3) Valmont Industries NER000003251, an LQG that was inspected on 8/19/2009 is not showing up on the inspection coverage for LQGs report.
 
New Jersey CAA For New Jersey data of the greatest accuracy, NJDEP offers access to data directly within its own data system online at http://www.nj.gov/dep/opra/online.html  
CWA For New Jersey data of the greatest accuracy, NJDEP offers access to data directly within its own data system online at http://www.nj.gov/dep/opra/online.html  
RCRA For New Jersey data of the greatest accuracy, NJDEP offers access to data directly within its own data system online at http://www.nj.gov/dep/opra/online.html  
New Mexico CWA 1.A.1 and 1A.3 - MAJOR AND MINOR UNIVERSE: We disagreed with the count of 35 majors and 88 minors as shown on the SRF. The count should be 34 majors and 89 minors, because the City of Raton (NM0020273) was counted as a major on the SRF; therefore it should be counted in the minor universe. It was a major that was downgraded to a minor when the permit was re-issued on 12/01/08. The enforcement section has asked the permits section in Region 6 to make a correction on the ICIS data base. The correction on the facility status should be correct before the data freeze.

1B.2 - MAJOR INDIVIDUAL PERMITS: DMR ENTRY RATE BASED ON DMRS EXPECTED: Take out the Region 9 facilities listed on Count and not Counted. Region six count is Count - 231 and Not Counted - 5. This count reflects taking out NN0020621 - NTUA Shiprock from (not counted) and NN000019 - APS Four Corners from (counted)

1B.3 - MAJOR PERMITS: Not counted should be (zero 0) take out NN0020621 - NTUA this is Region 9 facility.

1C.2 - NON-MAJOR PERMITS: DMR entry rate based on DMR expected - remove the Region
9 facilities listed on (Not Counted). Remove: NN0020800, NN0020869, NN0020915, NN0020958, NN0020991, NN0021016, NN0030325, NN0030335, The count for (Not Counted should be (45) instead of (53).

1C.3 - NON-MAJOR INDIVIDUAL PERMITS: DMR entry rate based on DMRs expected - remove the Region 9 facilities on (Not Counted) Remove: NN0020800, NN0020869, NN0020915, NN0020958, NN0020991, NN0021016, NN0028193, NN0029386, NN0030325, NN0030335, NN0030341, The count for (Not Counted should be (32) instead of (43)

8A.2 - SNC RATE: PERCENT MAJORS IN SNC: - remove two facilities from (Count) instead of (8) the (Count should be 6). Remove: NM0030848 - Buckman - the DMRs showing non-receipt are were received late. DMRR date is 10/13/09 ICIS is showing RNC Resol date as 10/13/09 for DMRs from 01/31/09 to 07/31/09, these DMRs should not show as violations.

NM0028169 - Mineral Engr. - the DMRs for 10/08 were received DMRR 01/05/09, RNC resol. date in ICIS is 01/05/09, RNC code is (2). This DMR should not show as a non-reporting violation.
 
New York CAA A problem with the translation of data between the state and EPA exists for stack test and MACT Subprogram data, so the data metrics do not reflect the complete number of stack tests reviewed by the state or MACT-affected facilities in the state.  
RCRA New York does not believe that several of the reports and counts are an accurate representation of activities and enforcement in the state for the RCRA program. For the 2008 Major Report, which is the latest Major Report for which the state was provided the universe for review, in the case of NY, the LQG universe they use is based on the universe from RCRA Info of 2062.

However, the number of LQGs from the 2007 Biannual Report was 1181. The National Program Managers Guidance subsequently allows the EPA regions in conjunction with the state to establish an alternative LQG universe on which to be evaluated. In the case of NY and EPA Region 2, an alternative 'Long Term' LQG universe of 721 facilities was established, and this LQG universe includes all but one TSD. During federal fiscal year 08, NY and EPA region 2 inspected 229 LQGs and 205 during federal fiscal year 09. The 08 Majors report, based on its erroneous criteria, showed that NY and EPA Region 2 had only inspected 11.4 percent of the 'Majors' for 08, while in fact, NY and EPA Region 2 had actually inspected 30.1 percent of the universe of LQGs and TSDs which have been agreed to within the annual RCRA C grant commitments between EPA Region 2 and NY.
 
North Carolina CWA Problems with the translation and timing of the data between EPA and the State exist for correctly coded limits, informal and formal actions, total penalties assessed and collected, inspections, unresolved permit schedule violations, and timely actions taken, so the data metrics do not reflect the complete number of activities performed by the State. Data Link (PDF) (4pp, 17 K)
North Dakota CWA Compliance Schedule violations for ND0000264 Montana Dak Utilities Mandan, ND0020079 Kenmare City of, ND0021342 Bowman City of, ND0022519 New Leipzig City of, ND0022799 Medora City of, and ND0023493 Mandan WTP have been resolved. The Three Year Compliance Status By Quarter is incorrect. These facilities have been in compliance with all compliance schedule items and have not been out of compliance during the past three years. North Dakota is working with EPA to correct these QNCR issues.  
Oklahoma CWA 1. Do to program commitments and manpower limitations, ODEQ does not code general & minor facility enforcement actions (metrics E.3, E.4, F.3, & F.4), inspections (metrics B.1 & B.2), or SEVs (metric A.2) into ICIS.

2.ODEQ's fiscal year (July-June ) is different than EPA's fiscal year (October-September), which has caused the discrepancy of the major inspection coverage (metric 5.A) to report fewer inspections than the actual value.

3. Metrics 7.B & 7.C (facilities with unresolved compliance and permit schedules) reflect the schedules for ODEQ's major facilities only.
Data Link 1 (PDF) (4 pp, 19 K)
Data Link 2 (PDF)  (2 pp, 9 K)
RCRA   Data Link (PDF) (1 pp, 53 K)
Oregon CAA   Data Link (PDF) (2 pp, 16 K)
CWA The state of Oregon has completed the review of CWA (NPDES) data. While Oregon DEQ submitted data to PCS throughout FY 2009, the State's data was not included in the routine Quarterly Non-Compliance Report processing schedule due to the PCS data backlog resolution project. Oregon did not receive the QNCRs in time to ensure quality data in PCS for FY 2009. This fact made the PCS data verification effort difficult. A large amount of the data could not be verified. Oregon DEQ would like to post the correction file to exhibit accurate information. Data Link (PDF) (4 pp, 12 K)
RCRA There is a discrepancy between RCRAInfo and Oregon's database in the number of LQGs. This is an issue with Oregon's BR translation that has caused sites to appear in RCRAInfo as LQGs when they are no longer in that universe.  
Pennsylvania CAA   Data Link 1 (PDF) (21 pp, 142 K)
Data Link 2 (PDF) (11 pp, 55 K)
CWA There is additional data available for Pennsylvania NPDES permitted facilities. State generated reports for Major and Non-Major Facilities are available in ECHO, under the State Review Framework Trend Data for Individual States. Data Link 1 (PDF) (4 pp, 37 K)
Data Link 2 (ZIP) (1151 K)
Rhode Island CWA Metrics associated with Stormwater permits are not accurately represented due to coding issues with biennial DMR reporting.  
South Carolina CWA A problem with the translation of data between the state system and EPA exists for DMR, schedules, and some enforcement data, so the data metrics do not reflect an accurate view of compliance and the activities performed by the state. South Carolina is continuing to work with EPA to resolve the issues.  
South Dakota CWA 1A3 = results show some wrongly coded EPA tribal permits along with several old CAFO permits there were to be deleted in PCS. These problems should be corrected. The correct number should be 272.

1A4 = is listed as having 88 General permits. There are 10 tribal permits that were not coded correctly by EPA so the correct number is 78

1B2 = SD is listed as having 93 of 94 permits. This is not correct. SD0020371 is listed as not counted and should be counted.

1B3 = SD is listed as having 27 of 29 permits with expected DMRs entered. There should only be 27 in the universe count because the other 2 have unscheduled limit sets or inactive limit sets only.

1C1 = These numbers are including several incorrectly coded EPA permit which are coded as state permits and is including permits with only unscheduled limit sets.

1C2/1C3 = The universe and counts columns are incorrect. They are including permits that only have unscheduled limit sets.

1D1 = The universe is again counted some incorrectly coded EPA permits as well as permits that only have unscheduled limit sets.

1E3 = The counts included an incorrectly coded sludge permit. This has been fixed.

5A0/5B1/5B2 = The data metric logic is not counting file review/desk audits so all inspection numbers are wrong. The metric is leaving out certain categories and types. The universe number is also including one facility that was on EPA Performance Tracking and did not require an inspection.

7B0/7C0 = The definitions in OTIS says for Majors however, it is believed that the data is suppose to be showing all facilities, which it is.
 
Texas CAA Data Metric 1.C. Clean Air Act subparts. During the first round of the SRF, EPA recommended TCEQ provide functionality to provide this data. The project is nearing completion and is scheduled to be fully implemented prior to August 31, 2010.

Data Metric 1.K. Major Sources Missing CMS Policy Applicability. This metric (35) is based on the current state of the data. TCEQ adds Major Sources on a continual basis. However, CMS Policy Applicability is determined just before the end of our fiscal year. The 35 represent newly permitted facilities which have not yet been flagged for compliance determination this fiscal year.

Data Metric 5. Inspection Coverage. TCEQ and EPA have agreed to a 3-year pilot project using a Risk-Based Investigation Targeting Strategy in place of the national CMS strategy. This metric is not representative of the agreement, which is covered under Element 13 of the SRF.
 
RCRA   Data Link (PDF) (1 pp, 9 K)
Utah CWA The State of Utah has completed the data verification for the 2009 State Review Framework CWA data. We have found differences in the minor permit count. Biosolids permits were included in the EPA count and should not have been because all but two were incorporated into municipal permits. The more accurate count of combined EPA and State minors is 96.

The penalty amount on formal enforcement is correct but not inclusive of Supplemental Environmental Project (SEP) expenditures. A SEP is an additional project or activity to benefit the environment, which the violator pays for in addition to a civil penalty.

The count of non-major general permits is misleading as this includes storm water industrial and construction facilities which can change daily due to permit expiration and project completion. The SRF database cannot reflect accurately this daily change in permitted facilities
Data Link (PDF) (1 pp, 6 K)
Virginia CWA The Virginia PPA/PPG agreement does not require NPDES permit limit or discharge information for the non-major individual and general permits or any inspection data for general permits to be sent to the EPA's database. Therefore, for such categories, information shown for FFY09 does not reflect the entirety of Virginia data and is not accurate or complete. DEQ facility inspection frequency is in accordance with the Virginia PPA/PPG.  
RCRA   Data Link (PDF)
Washington CWA   Data Link (PDF)  (6pp, 75 K)
RCRA A problem with the translation of data between EPA and the state exists for handler data, so the data metrics do not reflect the correct number of active sites in the state.  
West Virginia CWA The State of West Virginia has completed a portion of its review of CWA data. One data issue that WV has is that outfall and effluent data appears missing when the fact is that these are collection systems and outfall and effluent data doesn't apply. These are designated in the rdf10 field as 4952C facilities (collection systems).  
Wisconsin CAA Due to a programming error in our batch upload program no Compliance Certifications have been entered in AFS for FY09. When the programming problem is resolved the missing data will be entered. There is no timetable for completion of the programming work and uploading of those data.  
Wyoming CWA   Data Link (PDF) (1 pp, 30 K)

 

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