State Comments on Frozen Data - 2012

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.

2012 Comments on Frozen Data (Captured March 2013)
State Media Comments Data Links
Alabama CAA -Metrics 1A1 and 1A2 are flawed in that they use the DCL1 field which reflects both Title V and PSD Major and Synthetic Minor Sources even though the CMS policy targets Title V major and SM sources. These metrics should look at the "V" and "F" air programs only. Alabama has sources that are incorrectly included in these metrics because they are major or synthetic minor, respectively, for PSD due to our state's TSP regulations.
-Metric 1A4 is flawed in that it is comparing the currently classification of a facility to a historical CMS Code. Alabama adjusts its CMS universe annually. Alabama has never negotiated its CMS plan to include minor sources.
-Metrics 3A1 and 3A2 are not a reflection of Alabama's data entry timeliness. This data is entered into AFS by EPA personnel.
 
CWA -The final SRF values could be different than the values at the time comments are submitted since comments are due to EPA before the final refresh of the SRF data. Therefore, Alabama is including the SRF number from the last SRF refresh as compared to Alabama's actual value, verified by data contained in ICIS-NPDES database. 

-The SRF data value of 190 for Metric 1a1--Number of Active NPDES Majors with Individual Permits is consistent with the state projection of 190.

-The SRF data value of zero for Metric 1a2--Number of Active NPDES Majors with General Permits is consistent with the state projection of zero. 

-The SRF data value of 1,400 for Metric 1a3--Number of Active NPDES Non-Majors with Individual Permits is similar to the state projection of 1,402. 

-The SRF data value of 15,279 for Metric 1a4--Number of Active NPDES Non-Majors with General Permits (or total universe) is similar to the state projection of 15,215. 

-The SRF data value of 100% for Metric 1b1--Permit Limits Rate for Major Facilities is consistent with the state projection of 100%. 

-The SRF data value of 99.8% for Metric 1b2--DMR Entry Rate for Major Facilities is consistent with the state projection of 99.8%. 

-The SRF data value of 18 for Metric 1b3--Number of Major Facilities with a Manual Override of RNC/SNC to a Compliant Status is consistent with the state projection of 18.

-The SRF data value of 74.3% for Metric 1c1-- Permit Limits Rate for Non-Major Facilities is inconsistent with the state projection of 50%. In the past, ADEM has voluntarily entered permit limits for Mining minor permits. Metric 1c1 counts the "Permit Limits Rate for Non-Major Facilities" in the SRF Round 3 CWA Metrics Summary 12-28-2012. However, Metric 1c1, as well as many other metrics, counted the Mining minor DMRs even though they are not required. Therefore, in an effort to have more accurate metrics, ADEM removed the permit limits that were not required by EPA for these facilities.

-The SRF data value of 23.4% for Metric 1c2--DMR Entry Rate for Non-Major Facilities is not consistent with the state projection of 92%. In the past, ADEM has voluntarily entered permit limits for mining minor permits. Metric 1c2 counts the "Number of received DMRs as a percentage of the total number of expected DMRs" in the SRF Round 3 CWA Metrics Summary 12-28-2012. However, 1c2, as well as many other metrics, counted the Mining minor DMRs even though they are not required. Therefore, in an effort to have more accurate metrics, ADEM removed the permit limits that were not required by EPA for these facilities.

-The SRF data value of 2,099 for Metric 1e1--Facilities with Informal Actions is similar to the state projection of 2,100.

-The SRF data value of 2,204 for Metric 1e2-- Total Number of Informal Actions at CWA NPDES Facilities is similar to the state projection of 2,205. 

-The SRF data value of 78 for Metric 1f1--Facilities with Formal Actions is consistent with the state projection of 78. 

-The SRF data value of 77 for Metric 1f2-- Total Number of Formal Actions at CWA NPDES Facilities is similar to the state projection of 76. 

-The SRF data value of 55 for Metric 1g1--Number of Enforcement Actions with Penalties is consistent with the state projection of 55. 

-The SRF data value of $1,283,250 for Metric 1g2--Total Penalties Assessed is consistent with the state projection of $1,283,250. 

-The SRF data value of zero for Metric 2a1--Number of formal enforcement actions, taken against major facilities, with enforcement violation type codes entered is consistent with the state projection of zero. 

-The SRF data value was not reported on the most recent refresh for Metric 5a1--Inspection Coverage - NPDES Majors previously listed values were not consistent with the state projection of 98.95%. 

-The SRF data value of 27% for Metric 5b1--Inspection Coverage - NPDES Non-Majors is similar to the state projection of 28%.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description is incomplete. The SRF data value of 14.1% for Metric 5b2--Inspection Coverage NPDES Non-Majors with General Permits is similar to the state projection of 14.20%. 

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. However, the State was able to duplicate EPA's logic for selection criteria and found it to be inconsistent with the other Metric Criteria in that it includes historical violations as well. The data description for Metric 7a1--Number of Major Facilities with Single Event Violations is defined by EPA in the SRF Round 3 CWA Metrics Summary 12-28-2012 as "Number of major facilities with one or more single event violations during the fiscal year." However, based on the data selection criteria defined in SRF Round 3 CWA Metrics Summary 12-28-2012 "....continuing single event violations that were unresolved at the beginning of the FFY." The SRF data value of 1 for Metric 7a1 is consistent with the state projection of 1.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. However, the State was able to duplicate EPA's logic for selection criteria and found it to be inconsistent with the other Metric Criteria. The SRF data description for Metric 7a2--Number of Non-Major Facilities with Single Event Violations is defined by EPA in the SRF Round 3 CWA Metrics Summary 12-28-2012 as "Number of non-major facilities with one or more single event violations during the fiscal year." However, based on the data selection criteria defined in SRF Round 3 CWA Metrics Summary 12-28-2012 "Count facilities with SEVs that were entered in the fiscal year, or continuing SEVs that were unresolved at the beginning of the FFY." The SRF data value of 1 for Metric 7a2 is inconsistent with the state projection of zero.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. However, the State was able to duplicated EPA's logic for selection criteria and found it to be inconsistent with the other Metric Criteria in that it includes historical violations as well. The data description and data selection criteria for Metric 7b1--Compliance schedule violations is defined by EPA in the SRF Round 3 CWA Metrics Summary 12-28-2012 as "Of the permittees with compliance schedule milestones scheduled to be met in the FFY, the number of facilities with unresolved compliance schedule violations as of the end of fiscal year." The SRF data value of 85 for Metric 7b1 is inconsistent with the state projection of 5.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. However, the State has duplicated the logic for selection criteria and found it to be inconsistent with the other Metric Criteria in that it includes historical violations as well. The data description and data selection criteria for Metric 7c1--Permit schedule violations is defined by EPA in the SRF Round 3 CWA Metrics Summary 12-28-2012 as "Of the permittees with permit schedule milestones scheduled to be met in the FFY, the number of facilities with unresolved permit schedule violations as of the end of fiscal year." The SRF data value of 1 for Metric 7c1 is inconsistent with the state projection of zero.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. However, the State has duplicated the logic for selection criteria and found it to be inconsistent with the other Metric Criteria. The SRF data value of 56.30% for Metric 7d1--Major Facilities in Noncompliance is consistent with the state projection of 56.30%. 

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. The State has duplicated the logic for selection criteria and found it to be inconsistent with the other Metric Criteria. However, EPA informed Alabama through email correspondence on February 22, 2013, "We have found an error in the query code for metric 7f1, that caused the metric counts shown on the SRF site to be too low." The SRF data value of 754 for Metric 7f1-- Non-Major Facilities in Category 1 Noncompliance is inconsistent with the state projection of 376.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. The State has duplicated the logic for selection criteria and found it to be inconsistent with the other Metric Criteria. However, EPA informed Alabama through email correspondence on February 22, 2013, "We have found an error in the query code for metric 7g1, that caused the metric counts shown on the SRF site to be too low." The SRF data value of 126 for Metric 7g1-- Non-Major Facilities in Category 2 Noncompliance is inconsistent with the state projection of 74.

-EPA's SRF Round 3 CWA Metrics Summary 12-28-2012 guidance for Selection Criteria Description for Metric 7a1-7h1 is not clearly defined. The State has duplicated the logic for selection criteria and found it to be inconsistent with the other Metric Criteria. The SRF data metrics of 61.80% for Metric 7h1--Non-Major Facilities in Noncompliance is inconsistent with the state projection 32.2%.

-The SRF data value of 38 for Metric 8a1--Major Facilities in SNC is consistent with the state projection of 38.

-The State was not able to duplicate the logic for the selection criteria of Metric 8a2--Percent of Major Facilities in SNC. The state was unable to verify the SRF data value of 19.6%. EPA providing the query logic in the ICIS-NPDES system would assist states in verifying this information. 

-The State was not able to duplicate the logic for the selection criteria of Metric 10a1--Major facilities with Timely Action as Appropriate. The state was unable to verify the SRF data value of 0%. EPA providing the query logic in the ICIS-NPDES system would assist states in verifying this information.
 
Alaska CAA A problem with the translation of data between EPA and the State exists for facility classification and air programs so the Data Metrics do not reflect the State's facility classification.  
Arizona CAA Nucor Steel Kingman (04015Z2455) is incorrectly included under Air Quality Metric 1d1 (Tier Is with noncompliance identified during FY 2012) for the State of Arizona data. The error occurred when Nucor Steel was de-archived in AFS during FY 2012 upon starting up operations and was tagged as noncompliant when an old (2001)unresolved HPV from a former company mistakenly showed up in ECHO under Nucor Steel due to the old HPV resolving action not being entered when it occurred in 2001. The HPV resolving action was put into AFS in January 2013 and ECHO now accurately shows Nucor Steel as being in compliance during FY 2012, but the listing under Metric 1d1 could not be removed. Nucor Steel was in compliance with their permit at all times during FY 2012.  
Arkansas CAA -Metric 5a - Two facilities identified as not within coverage are not being picked up by report.

-Metric 5b - Two facilities identified as not within coverage are not being picked up by report.

-Metric 1b1-0510700013-ADM Grain is not being counted in the state count but is being counted in the Federal system. In AFS correctly recurring problem.

-Metric 10A-0510900017 Bean Lumber is NIO and unable to locate permit holders.
 
CWA -Number of Active NPDES Non-Majors with General Permits (SRF CWA Metric 1a4) - 263 of the facilities counted in metric 1a4 have expired without submitting a renewal application or a notice of termination (NOT); therefore, the permit coverage has been deemed invalid. Since ADEQ has not received NOTs from these facilities, they have not been terminated in ICIS. ICIS does not provide a permit activity status for permits that have expired without renewal. ADEQ does not believe these permits should be counted as "Active Non-Majors with General Permits". 

-Number of Major Facilities with a Manual Override of RNC/SNC to a Compliant Status (SRF CWA Metric 1b3) - The manual overrides of the RNC Status for the three (3) facilities counted in metric 1b3 were performed to correct a known system error in US EPA's ICIS-NPDES database. Therefore, no negative implications should be drawn from these manual settings.

-Facilities with Informal Actions (SRF CWA Metric 1e1) - Normally, ADEQ enters Informal Enforcement Actions for Major permits only. Informal enforcement actions such as Notices of Violations that precede a Default Administrative Order may be entered for non-major facilities.

-Compliance schedule violations (SRF CWA Metric 7b1) - Compliance Schedule Violations for eight (8) of the Arkansas NPDES facilities counted in metric 71b are from Enforcement Actions issued by U.S. EPA (AR0000752, ARR10A987, ARR10C780, ARR150775, ARR150985, ARR151050, ARR151661, ARR152383). Arkansas does not track schedule events established by orders issued by US EPA. Should these violations be listed with the "State" metrics?

-Non-Major Facilities in Category 1 Noncompliance (SRF CWA Metric 7f1) - We suggest that metric 7f1 be renamed to "Non-Major Facilities with Serious Noncompliance", since this metric does not seem to correspond to the definition of Category I noncompliance in 40 CFR 123.45. 

-Non-Major Facilities in Category 2 Noncompliance (SRF CWA Metric 7g1) - We suggest that metric 7g1 be renamed to "Non-Major Facilities with Less Serious Noncompliance", since this metric does not seem to correspond to the definition of Category II noncompliance in 40 CFR 123.45.

-Major Facilities in SNC (SRF CWA Metric 8a1) - The QNCR regulations (40 CFR 123.45) states that a permittee that is under an enforcement order, in compliance with the enforcement order, but has not achieved full compliance with permit conditions, the compliance status shall be reported as "resolved pending," on the QNCR. Therefore, permits AR0001775, AR0021971, AR0022560, AR0022578, AR0037176, and AR0046566 should be excluded from metric 8a1.
 
California RCRA
Regulation of hazardous waste in California is a partnership between federal, state and local agencies. TSDFs and TSDFs that are also LQGs are regulated by the state; most LQGs and all SQGs are regulated by 83 local agencies. Data for RCRA inspections, violations, and enforcement actions conducted by the California Department of Toxic Substances Control is currently uploaded monthly from EnviroStor Data System to EPA's RCRAInfo. Data on inspections, violations and enforcement from California local agencies is uploaded weekly from CERS, which has been in transition to a full digital exchange and is approximately 50% loaded. 
 
LQG Specific: RCRAInfo includes a significant number of facilities self-identified as LQGs that have not been updated by business for decades. California does not use RCRAInfo as a management tool and does not routinely update it. The state has identified approximately 1,900 facilities as actual LQGs, while RCRAInfo identifies over 5,000 LQGs. Additionally, California has historically reported only the LQG inspections to RCRAInfo, not the SQG inspections. In fiscal years 2012 and 2013, the state’s automation project interfered with the complete reporting of LQG inspections and this resulted in the apparent decline in the number of inspections. California conducted well over 1,000 LQG inspections in both fiscal years 2012 and 2013. As California continues to fully automate reporting, all hazardous waste generator inspections, LQG and SQG, will be reported to RCRAInfo. In the last five fiscal years, California conducted over 30,000 hazardous waste generator inspections each year.
 
Colorado CAA We strongly disagree with metric 1b4 and the way it is pulled for the SRF. Colorado's universe of reportable Title V Facilities is about 239. The way this metric is pulled appears to include anything that has a V air program, but should ONLY include sources that actually have a Title V permit.

We also disagree with the findings of metric 5b concerning FCE Coverage SM-80 sources that show we have completed only 62% of FCEs. Over the last 3 years, we have conducted FCEs on nearly 100% of our universe which is more conservative than the 5 year rotation allowed for FCE coverage for SM-80s.
 
CWA -1a4 - We have approximately 6,000 general permit certifications for stormwater that are not currently entered in the ICIS database. 

-1e1 and 1e2 - Colorado does not enter informal actions into the ICIS database.
 
Connecticut CWA Metric 1a3: Number of Active NPDES Non-Majors with individual Permits
  • CTP000639 Medtronic Xomed in Mystic, CT is erroneously listed as an NPDES Non-Major. This is a pretreatment permit.
  • CTP002298 The Gillette Company in Bethel, CT is erroneously listed as an NPDES Non-Major. This is a pretreatment permit.
Metric 1a4: Number of Active Non-Majors with General Permits: 159
  • This number reflects a fraction of the facilities with NPDES general permits. CT does not routinely enter General Permits into ICIS. Those listed were entered into ICIS because CT DEEP has performed inspections of them at some point in the past. Most listed are Stormwater GP registrants. The universe of Industrial Stormwater GP registrations alone is over 1,500.
Metric 1e1: Facilities with Informal Actions Metric 1e2: Total Number of Informal Actions at CWA NPDES Major Facilities
  • CT does not enter informal actions (NOVs) into ICIS but will do so going forward, as EPA recently provided CT ICIS training on how to do so. CT currently tracks informal actions in a state-run database.
Metric 1f1: Total Number of Formal Actions
Metric 1f2: Total Number of Formal Actions at CWA NPDES Facilities 
Metric 1g1: Number of Enforcement Actions with Penalties 
Metric 1g2: Total Penalties Assessed
  • These metrics (1e1 through 1g2) listed administrative orders issued by CT DEEP
  • They did not include Stipulated Judgments and related penalties, which resulted from referrals to the Attorney General's Office.
  • CT DEEP recently received training from EPA on how to enter such data into ICIS and entered the FFY2012 data, and will continue to do so going forward.
  • The following Stipulated Judgments were recently entered into ICIS for FFY2012:
    • Kohler Mix Specialties, LLC located at 100 Milk Lane in Newington; Pretreatment Permit No. SP0002278 (No. CTP002278 in ICIS); Penalty $299,999.
    • Haynes Construction Co., located at 32 Progress Avenue in Seymour and Mountain Road Estates, LLC located at 32 Progress Avenue in Seymour; General Permit for the Discharge of Stormwater and Dewatering Wastewaters from Construction Activities, Permit No. GSN001378, for a residential housing development known as Meadow Brook Estates located in Oxford and Seymour; Penalty $50,000.
    • New Home Building Services, LLC located at 580 Broad Street in Bristol; General Permit for the Discharge of Stormwater and Dewatering Wastewaters from Construction Activities; for a residential housing development known as Table Rock Estates located at Angela's Way in Burlington; Penalty $25,000.
Metric 5b2: Inspection Coverage - NPDES Non-Majors with General Permits
  • This % metric is erroneous, as the universe count is erroneous. See comment for Metric 1a4.
  • The number of facilities inspected is also erroneously listed as 2. There were 54 inspections for facilities covered by Stormwater General Permits alone.
  • In October 2012, CT DEEP verified that inspections for FFY2012 were entered in ICIS, so it was not understood why they are not accounted for in the OTIS SRF statistics. CT DEEP is working with EPA HQ to investigate the cause of the discrepancy. EPA has identified additional ICIS fields that need to be filled in for inspections to be counted by the metrics. CT DEEP has gone back and input this data before the March 14th deadline. However, CT DEEP has posed additional specific questions it has posed to EPA about entering Stormwater inspection data into ICIS that have not been addressed yet. CT DEEP will continue to work with EPA on this matter.
Metric 7a1: Number of Major Facilities with Single Event Violations Metric 7a2: Number of Non-Major Facilities with Single Event Violations
  • CT does not currently enter SEVs into ICIS. EPA recently provided training to CT DEEP on how to enter such data. CT will start entering SEV data into ICIS on a going forward basis.
Metric 7b1 : Compliance Schedule Violations
  • ICIS was updated with the following corrected information
    -CT0100251, Hartford WPCF was incorrectly listed in this metric. The schedule is complete.
Metric 7d1: Major Facilities in Noncompliance
  • CT0020826, Auto Swage Products, Inc., in Shelton
    • ECHO is not flagging certain "D" (non-report) violations for certain parameters for June and Sept 2012 DMRs.
    • Effluent monitoring data was not submitted for the following parameters on the June 2012 DMR:
      * Cadmium, total kg/d (Monthly average & Daily maximum)
      * Silver, total kg/d (Monthly average & Daily maximum)
    • Effluent monitoring data was not submitted for the following parameters on the Sept 2012 DMR:
      * Oil & Grease(Daily average & Daily maximum)
      * Nitrogen, ammonia total (Daily maximum)
      * Cadmium, total mg/l (Monthly average & Daily maximum)
      * Cadmium, total kg/d (Monthly average & Daily maximum)
      * Chromium, total (Monthly average & Daily maximum)
      * Iron, total (Daily average & Daily maximum)
      * Silver total mg/l (Monthly average & Daily maximum)
      * Silver total kg/d (Monthly average & Daily maximum)
      * Palladium, total Daily maximum
      * Surfactants (MBAS) Daily maximum
      * Gold, total (Daily average & Daily maximum)
      * Total Toxic Organics, Instantaneous maximum
      * Chemical Oxygen Demand, Daily maximum
      * LC50 Acute D. Pulex, Daily minimum
      * LC50 Acute Pimephales, Daily minimum.
  • CT0003131, Styron, LLC, in Ledyard
    • For DSN 001-1 in June 2012, ECHO shows an erroneous violation of chronic toxicity (parameter code TPP3E): NOEC = 5%. That parameter code was replaced and does not appear in NetDMR. Parameter code TYP3E appears in NetDMR with the correct data of 100%, which is not a violation.
  • CT0100960, Town of Putnam WPCF
    • DSN 001-1 shows erroneous effluent violations for Total Phosphorus. The concentration limitations for Total Phosphorus do not go into effect until May 10, 2015. The effective date of the Phosphorus limitation has been corrected in ICIS.
  • CT0000434, Ahlstrom Power in Windsor Locks
    • ECHO shows a violation occurring in the quarters April - June and July to Sept 2012. However, there are no violations shown in ICIS for that time period. EPA Region 1 was notified of the error.
Metric 7g1 : Non-Major Facilities in Category 2 Noncompliance
  • EPA was notified of the following errors, and corrections were requested. We are including these in the Data Caveats in case the corrections are not made by the March 14, 2013 deadline.
    • CTP002298 The Gillette Company in Bethel is erroneously listed in this metric. This is a pretreatment permit.
    • CT0000906, Tilcon Connecticut Inc., 190 Totoket Rd, in Branford is incorrectly listed in this metric.
      -ECHO incorrectly shows a violation occurring during the quarter January to March 2012. The permit requires quarterly DMR submittals. The DMR for that quarter was submitted on time and indicates there was no discharge. This is reflected in ICIS, where there are no violations noted.
    • CT0003441, Windsor Stevens, Inc., in Windsor is incorrectly listed in this metric.
      -ECHO incorrectly shows a violation occurring during the quarter January to March 2012. ICIS reports no violations during this quarter.
    • CT0003751, Fusion Paperboard Connecticut, LLC, in Sprague is incorrectly listed in this metric.
      -ECHO incorrectly shows a violation occurring during the quarter April to June 2012. There is no reported violation in ICIS.
Metric 8a1 : Major Facilities in SNC
  • CT0100960, Town of Putnam WPCF
    -This permit is not in SNC. The violations that triggered SNC status are erroneous as explained in Metric 7d1. ICIS programming was corrected in early February 2012, but we are including this caveat as a precaution, as it still displays in ECHO as of the date this is being reported (3/14/13).
 
RCRA Connecticut inspected five more large quantity generators (LQGs) than shown on the Hazardous Waste Dashboards. The CT Hazardous Waste Activity Dashboard, Facilities Inspected by Facility Type chart, shows a total of 58 inspections at LQGs; however, CT Department of Energy and Environmental Protection (DEEP) screens its manifest database and inspects facilities that appear to be operating out of their notified status. DEEP identifies SQGs, CESQGs, and non-notifiers operating as LQGs and shipping greater than 1000 kg of hazardous waste possibly without complying with applicable requirements. CT regulates any generator accumulating 1000kg of hazardous waste as a LQG. These facilities are commonly inspected as LQGs based on the operating status at the time of the inspection and/or the pre-inspection records review. However, as a result of DEEP enforcement action, these LQGs generally come back into compliance with their SQG or CESQG status, which results in safer management of smaller quantities of waste. The inspections are entered into the RCRAInfo data system and are to be counted as LQG inspections for the fiscal year. In FY 2012 CT DEEP conducted 5 manifest inspections, brings the total number of LQG inspections up from 58 to 63.  
District of Columbia CAA Four compliance issues were corrected in AFS on 3/14 and 3/15/2013, but may not be reflected in the final data snapshot. Specifically:
  • Washington Hospital Center - 11/001/00014 compliance status was changed to compliance for the full year from "meeting schedule".
  • Bolling Air Force Base - 11/001/00061 compliance status was changed to in compliance from "meeting schedule" for the full year except May 2012 which was changed to "in violation with regard to emissions".
  • Washington Hilton and Towers - 11/001/00150 - The Title V air program was changed from "in violation - not meeting schedule" to in compliance.
  • Sibley Memorial Hospital - 11/001/00054 - Compliance status of the VOC and NO2 pollutants were previously listed as in violation and unknown, respectively. They were changed to in compliance.
  • St. Elizabeths Hospital - 11/001/0009 - an annual certification review for CY2011 had been inadvertently entered when no such certification was received. This review was deleted.
 
Florida CAA Florida continues to work with EPA Region 4 to correct the historical compliance status for a couple of facilities in AFS.  
CWA 1a1 - This number should be 216. Two Phase I MS4 permits are mislabeled as minor permits in ICIS. Staff in Florida is working to correct this issue. 25 of the 214 listed are stormwater (MS4) permits that do not have monitoring requirements; only 189 NPDES wastewater.

1a2 - This number is accurate. Florida has no general permits for major facilities.

1a3 - This metric includes nine facilities that are improperly labeled as non-major individual permits, seven of which should be listed as general permits (concrete batch plants) and two of which are Phase I MS4 permits (Leon County and City of Bradenton). Staff in Florida is working to correct this issue.

1a4 - Five permits listed are Alabama permits, not Florida, & need to be removed. Also, the value reported here includes 3,846 NPDES Stormwater permits that were expired in ICIS and have been recently terminated. Staff in Florida is working to remove all expired CGPs and MSGPs from ICIS to more accurately reflected the permitted universe of non-major general permits.

1b3 - Manual overrides verified and performed by EPA Region 4 staff. These overrides are for facilities that are on the Watch List for missing data issues. Overrides are performed in order to expedite removing the facility from the Watch List once the missing data issues have cleared.

1e1 - This number does not reflect the NPDES Stormwater numbers from the State of Florida. The total should be 131. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

1e2 - This number does not reflect the NPDES Stormwater numbers from the State of Florida. The total should be 134. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

1f1 - This number does not reflect the NPDES Stormwater numbers from the State of Florida. The total should be 80. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

1f2 - This number does not reflect the NPDES Stormwater numbers from the State of Florida. The total should be 81. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

1g1 - This number does not reflect the NPDES Stormwater numbers from the State of Florida. The total should be 28. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

1g2 - While this number appears to coincide with the amount of penalties assessed for IW and DW facilities by the State of Florida, it does not include the NPDES Stormwater penalties assessed. Adding the NPDES stormwater numbers in would equal $411,508. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

2a1 - This number appears to be accurate for NPDES wastewater facilities. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

7a1 - This number appears to be accurate.

7a2 - This number appears to be accurate for NPDES wastewater facilities. Florida does not enter NPDES Stormwater enforcement data into ICIS per our 106 work plan agreement, but submits quarterly reports to EPA Region 4 staff.

7b1 - This number appears to be accurate.

7c1 - This is a PCS to ICIS migration issue. The migration caused an enforcement action compliance schedule to appear as a permit schedule. The enforcement action was closed on 10/11/2011, therefore, no compliance schedule violation. Florida staff is working to update ICIS.

7f1 - Numbers appear to correlate with the QNCRs for FY2012.

7g1 - Numbers appear to correlate with the QNCRs for FY2012.

8a1 - Numbers appear to correlate with the QNCRs for FY2012.
 
Georgia CAA GA EPD continues to experience some problems with US EPA's database accepting NSPS/NESHAP/MACT subpart corrections, accepting NSPS/NESHAP/MACT applicability corrections, and accepting source operating status (O, C, T, P, X) corrections.  
Illinois CAA All known current and past compliance status errors discovered by Illinois EPA during data verification have been corrected in USEPA's AFS system. Illinois EPA was unable to verify that the corrections in AFS effectively changed the data in the data verification tables and the Illinois Dashboard information because a refresh of the data was not available. Further compliance status errors could exist.  
Indiana CAA Regarding Metrics 1a3, 1a4, 1b1, 1b2, and 1b3, Indiana recognizes that these counts are not accurate and both Indiana and the EPA are continuing to work together to improve NSPS and NESHAP data in AFS.

Regarding Metrics 1a5, 1a6, 1d1, and 1d2, based on historical database inaccuracies made by EPA and/or the state, the sources listed may not have had violations or compliance status issues within the federal Fiscal Year 2012 period in question. IDEM continues to work with EPA to improve current data quality and accuracy regarding compliance status on these facilities.
 
RCRA 1a1 - The universe number for TSDs should not include the state owned facility of Purdue since we are not required to inspect this facility 

1e2 - 17 of these have an SNN date in RCRAInfo & should not be on the SRF list 

2a - The count should be 36; 8 are EPA lead which the state cannot fix; 13 were SNC but the SNC status was removed due to an Agreed order 

5a - This should be 100% since the state owned facility should not be counted as being in the universe 

5b & 5c - The count of LQGs is based on the 2009 Biennial report which is out of date. Indiana commits each year to do 20% of the number of LQG facilities active in RCRAInfo at the start of the state fiscal year per our EnPPA. We do nearly 100% of those inspections excluding only some facilities which were 1x generators, bridge projects, or commercial department stores who are intermittent LQGs. 

5e3 - This measure is based on a non-notifier flag of 'N' with the extract flag marked as "yes". Indiana does a great many inspections at facilities with UO or UW violations that are not coded as non-notifier because they are not required to notify. They are also not flagged to extract because we don't want our in-house Identification number released to the public.
 
Kentucky CAA The data in AFS is reasonably consistent with the data in Kentucky's TEMPO database with the following exceptions:
  • Metric 1C1 State- Number of tier 1 facilities with an FCE
    AFS- 224, TEMPO-371
    There were 141 more FCE's done that show up in TEMPO that do not show up in AFS. The reason that some of these actions did not make it to AFS is not clear but is being investigated.
  • Metric 1i1 State- Number of stack tests with passing results
    AFS- 60, TEMPO 184
    There were 124 more tests that were approved in TEMPO in FY2012 than showed up in the SRF (AFS) data. The reason for this is unclear but it is speculated that the test had to be performed and approved in FY2012 for it to show up in the SRF (AFS) data to verify. Since many of these tests may have been performed in FY2011 or before and not approved until FY2012 it is speculated that this could be the reason for the discrepancy.
  • Metric 1J State- Number of Title V Annual Compliance Certifications Reviewed This metric says Title V but is including all majors (Title V and synthetic minors).
    AFS-405, TEMPO 475
    TEMPO has 70 more ACC reviews. The reason some of these actions did not make it to AFS is not clear but is being investigated.
The most accurate information resides in the TEMPO database and therefore the Kentucky Division for Air Quality should be contacted for accurate information. Specifically, Deanna Picklesimer should be contacted at 502-564-8158, extension 4454 or by e-mail at Deanna.Picklesimer@ky.gov.
 
CWA The Kentucky Department for Environmental Protection has verified the FFY2012 data for the NPDES program and certifies the data with the following caveats:
  • Effluent limits for KPDES permits issued to surface coal mining facilities are not coded into ICIS-NPDES.
  • DMR data for surface coal mining facilities are not entered into ICIS-NPDES.
  • Informal enforcement actions (Notices of Violation, Letters of Warning) are inconsistently entered into ICIS-NPDES.
  • KPDES compliance and enforcement activities at surface coal mining operations performed by the Kentucky Department for Natural Resources in conjunction with SMCRA inspections are not entered into ICIS-NPDES.
For information related to these caveats, please contact Tom Gabbard (502-564-3410) or Mark Cleland (502-564-2150).
 
RCRA Invalid data was contained in the LQGs not inspected (5c on the Matrix) in the last 5 years. Four facilities with invalid EPA ID #s were included in the count. The facilities had these numbers because they filed their biannual reports electronically with Region 4 with the incorrect numbers. Region 4 has told us these facilities cannot be removed from RCRA Info. These should not be considered in the count. The facilities erroneously listed are:
  • Steel Technologies KY0000639424
  • Osram Sylvania KYD006339000
  • IPSCO Tubular KYD991227112
  • Continental Crushing KYR055105290
The actual number for matrix 5c should be 7.
 
Maine CWA Maine DEP respectfully does not concur with the total number of State Non-Major Facilities in Category 1 and Category 2 Noncompliance. We worked with Region 1 staff to obtain an extract of FFY12 data which show 100 facilities in Category 1 and show 63 in Category 2, respectively. We maintain these totals to be correct.  
Michigan CWA Michigan continues to have data problems with getting some data into ICIS. We have reviewed the summary data available through the website and noted several problems. Inspection and enforcement actions are undercounted. The numbers of non-majors with individual permits or covered by general permits are in error. There are a number of other errors which we elaborated on last year. 

We are not able to correct the data at this time due to staff resource constraints. The data problems in EPA's database (ICIS) revolve around moving data to ICIS, not in capturing data. We believe our database holds most, if not all, of the required data. With the help of EPA Region 5 staff, some of our inspection and enforcement data has been loaded into ICIS. Last year's report contains a history of how this came about. We have moved forward to develop data flows for much of the required data. Unfortunately, technical issues outside of DEQ's immediate control have slowed the implementation of these data flows from our database to EPA's database. We are hopeful those issues will be resolved in the coming months. Once these systems are in place and operational, we'll be able to devote staff resources to addressing other issues with our data. We continue to work with the EPA Region 5 staff to resolve ICIS data issues. 

We are currently in the process of developing a new database. We expect to have a contractor on board in mid-April and a new system in place within 2 years. The requirements for our new database will include full data upload to ICIS.
 
Minnesota CAA Timeliness guidelines for reporting of Enforcement Actions to AFS cannot be met for Minnesota enforcement actions as they must wait until they become public documents before data about the case can be provided for entry into AFS. This date varies depending upon the type of enforcement action in Minnesota, but is well after the discovery date, and equals the date of settlement for stipulation agreements, and date of end of the appeal period for administrative penalty orders.

Timeliness guidelines for Stack Tests cannot be met because test reports are not due at the MPCA until 45 days after test completion. The test report review and verification letter then must be completed.
 
CWA The Minnesota Pollution Control Agency has made all reasonable effort to verify and correct the data presented in the OTIS/ECHO State Review Framework environment.

This has been done by ensuring that the data contained in the respective EPA program systems, ICIC-NPDES, RCRAInfo and AFS are in agreement with the Delta data system maintained by the MPCA as implementer of these programs for the State of Minnesota. Where discrepancies still exist, they are often beyond the control of the MPCA because they are related to the procedures by which the EPA IDEA/OTIS/ECHO database aggregates and assesses the data stored in the stand-alone program systems. The MPCA is unable to correct or influence any errors that arise in this process, which is wholly within the control of the EPA. For complete and current information on regulated parties in Minnesota, the MPCA suggests that data be accessed through our What's in my Neighborhood website.
 
Mississippi CAA Metric 3a2 Untimely Entry of HPV Determinations - MDEQ's business process for entering enforcement MDRs into AFS is based on making an accurate HPV/non-HPV determination before beginning the data entry. MDEQ enters data into AFS via EPA's Universal Interface and linking of enforcement actions to a Day Zero is least complicated when the Day Zero already exists. Therefore, NOVs are entered at the time the Day Zero is entered. Changing a HPV Day Zero action to a non-HPV Day Zero, and vice versa, is a very complicated process requiring assistance from EPA Region IV staff and potentially EPA Headquarters staff. Therefore, we take the time, which often involves reviewing a source's response to our NOV, to make the correct HPV determination. This ensures our data entry is as accurate as possible and limits having to change a Day Zero. Data entry occurs promptly after the HPV determination. 

Metric 3b2 Timely reporting of stack tests minimum data requirements - This metric evaluates the timely entry of stack test review results. The deadline for data entry begins from the date the stack test was conducted. Permits typically allow a company 45 to 60 days to submit a stack test report after conducting the test. MDEQ enters stack test data following staff review of the report and therefore, the metric is sometimes exceeded. 

Metric 3b3 Timely reporting of enforcement minimum data requirements - MDEQ's business process for entering enforcement MDRs into AFS is based on making an accurate HPV/non-HPV determination before beginning the data entry. MDEQ enters data into AFS via EPA's Universal Interface and linking of enforcement actions to a Day Zero is least complicated when the Day Zero already exists. Therefore, NOVs are entered at the time the Day Zero is entered. Changing a HPV Day Zero action to a non-HPV Day Zero, and vice versa, is a very complicated process requiring assistance from EPA Region IV staff and potentially EPA Headquarters staff. Therefore, we take the time, which often involves reviewing a source's response to our NOV, to make the correct HPV determination. This ensures our data entry is as accurate as possible and limits having to change a Day Zero. Data entry occurs promptly after the HPV determination.
 
CWA Metric 5b1 Inspection Coverage NPDES Non Major Individual Permits - This data represents the Non-Major NPDES facilities that had an inspection completed for FY12. The logic used in this data metric does not include inspections that were performed at Non-Major NPDES facilities that are now inactive. In FY12, 10 evaluations were conducted at facilities that are now inactive which are not represented in this metric. 

Metric 5b2 Inspection Coverage NDPES Non Major General permits - This data represents the Non-Major NPDES facilities that had an inspection completed for FY12. The logic used in this data metric does not include inspections that were performed at Non-Major General permit facilities that are now inactive. In FY12, 19 evaluations were conducted at facilities that are now inactive which are not represented in this metric.
 
RCRA Metric 5b Annual inspection coverage for LGQs (1FY) - The LQG universe used in this metric corresponds to the number of LQGs that filed a report for the BRS reporting cycle 2011. Mississippi's LQG universe has changed significantly since then. Metric 1A2 is a more accurate representation of Mississippi's LQG universe for FY12, and should be the universe used to measure inspection coverage.

Metric 5c Five year inspection coverage for LGQs - The LQG universe used in this metric corresponds to the number of LQGs that filed a report for the BRS reporting cycle 2011. Mississippi's LQG universe has changed significantly since then. Metric 1A2 is a more accurate representation of Mississippi's LQG universe for FY12, and should be the universe used to measure inspection coverage.
 
Montana CWA Some Metrics contain comments on specific permits, for more detailed information please contact Montana Department of Environment Quality.  
RCRA MDEQ noted a discrepancy in the total of active LQGs (1a2) and SQGs (1a3) at the end of the 2012 fiscal year from what the SRF report shows and what is actually in the RCRAInfo database. The discrepancy for metric 1a3 also affected the count in metric 5d (correct counts: 65/104/39).  
Nebraska RCRA Number of active LQGs and SQGs should change due for facilities that should submit subsequent notifications.  
Nevada CWA Data is correct in ICIS. At this point OTIS is still showing 10 missing DMR's which have been corrected in ICIS.  
New Hampshire RCRA 17 of the 25 sites inspected identified in metric 1b1 were, and are still, LQGs at the time of the inspection using more current information (as of 7/20/11)than the 2009 BRS. This adjusts the count for NH in metric 5b from 11 to 18 LQGs inspected for FFY 2012.TGL  
New York CAA New York State does not have the resources to verify every single piece of the thousands of pieces of data contained in the FFY 2012 CAA SRF data. However, we believe in most cases that the data batch uploaded from the NYSDEC system to EPA AFS is accurately portraying our universe of facilities, applicable programs and recorded violations.

In contrast NY does not believe that all of the underlying data to generate the timeliness metrics contained in Metric IDs 3, 5, 7, 8 & 10 are part of the data that we can easily verify in this process. As such we have focused our resources on assessing the accuracy of the metrics that do not have a timeliness element to them.
 
RCRA NYSDEC does not use the federal generator status field in RCRAInfo to track a site's RCRA hazardous waste generation status (ie LQG, SQG) and this field is inaccurate for NY sites. We use an internal database of manifest and Hazardous Waste Report data of HW shipments and generation instead. NY also does not use the active site field in RCRAInfo.

This results in the calculation of certain RCRA State Review Framework Metric #s being inaccurate: 1.a.2., 3., and 4., about # of sites in each generator category; and 5.b., c., and d., about inspection coverage. Any other calculations using these numbers would also be inaccurate. The percent of NY LQGs and SQGs inspected, or inspection coverage, is greater than calculated in the metrics. These numbers are based on current universe counts for LQGs and SQGs, but since these universes change on a daily basis, some of the LQG/SQG inspections conducted are not credited in EPA's SRF reports because the site moved out of the universe, and their generator status field in RCRAInfo was not revised.

This also results in the data at ECHO's Search Compliance Data (Hazardous Waste Program), Enforcement Performance Dashboards and Comparative Maps, and Envirofacts public webpages not displaying a NY site's generator status correctly.

For Metric 5a, Two-year inspection coverage for operating TSDFs, EPA Region 2 staff inspected four TSDFs that the state NYSDEC did not. The Combined/All metric results show 100 percent inspection coverage.

EPA R2 and NYSDEC have agreed to target inspections at long-term LQGs, since a very large percentage of our LQGs are an LQG for a year or less. Inspecting sites that don't generate hazardous waste on an ongoing basis is difficult.

5-10 inspections (violations and enforcements) have not been entered because no RCRA EPA ID # has been issued to the site by EPA R2.

NY conducts inspections at facilities that do not have EPA ID#s and are not required to notify EPA nor NYSDEC of their hazardous waste activities (i.e. federal CESQGs, and non-regulated facilities) nor get an EPA ID#. The inspection activities, enforcement actions, and resulting monetary penalties assessed or collected as a result of such enforcement activities by NY are not captured or reflected in the EPA metrics. As a result, EPA's metrics understate NY's full range of hazardous waste compliance, inspection, and enforcement efforts. 

Inspection and enforcement data has not been entered for some SQGs where enforcement is pending, and the sites don't have an EPA ID # yet, because their failure to obtain an ID is part of the enforcement. Without an ID, we can't enter any data.

Not all data was entered in RCRAInfo before EPA's deadline of 2/26/2013.
 
North Carolina CAA 1a2 - Charles D. Owen Manufacturing Company was actually a small source in 2012, not a synthetic minor source. The state classification has been changed to reflect this.

1a6 - Number of Active Minors and Facilities with unknown classification subject to a Formal Enforcement Action that are Federally-Reportable 
5 NC Minors facilities with formal enforcements were not included in total.
  • 37-081-01080 - Guilford Plating Company
  • 37-027-00177- City of Lenoir - Lower Creek WWTP, Biosolids Facility
  • 37-109-00043 - McMurray Fabrics, Inc. - Lincolnton
  • 37-009-00140 - Carolina Counters Corporation
  • 37-003-00061 - Radford Quarries of Boone, Inc.
Total for this Metric for NC is 6

1b1 - Number of Active Federally Active NSPS Part 60 Facilities
7 NC Facilities are not subject to NSPS Part 60. The Air Program NSPS Part 60 was still listed as operating in AFS for these facilities.
Total for this Metric for NC is 542

1b4 - Number of Active Federally-Reportable Title V Facilities
1 NC Facility was issued a TV permit in FY2012. TV Air Program from the permit issued was keyed in NC's database after the review period. The TV Air Program for this facility has been now added in AFS.
Total for this Metric is 309

1c1 - Number of Tier I Facilities with FCE
1 NC Facility was changed CMS class during FFY2012 (Synthetic Minor to Minor). As a result, the FCE when the facility was a Synthetic Minor was not counted. The FCE for this facility was conducted be before the CMS class change date.
Total for this Metric is 1049

1c2 - Number of FCEs at Tier I Facilities
1 NC Facility was changed CMS class during FFY2012 (Synthetic Minor to Minor). As a result, the FCE when the facility was a Synthetic Minor was not counted. The FCE for this facility was conducted be before the CMS class change date.
Total for this Metric is 1052

1d1 - Number of Tier II Facilities with Non compliance Identified
9 NC Tier II Facilities with Non compliance were not counted for FFY2012. 
Total for this Metric is 129

1g3- Number of Formal Enforcement Actions issued to Tier II Facilities
6 NC Formal Enforcement Actions issued to Tier II were not counted for FFY2012.
Total for this Metric is 6

1g4- Number of Tier II Facilities subject a Formal Enforcement Actions
6 NC Formal Enforcement Actions issued to Tier II were not counted for FFY2012.
Total for this Metric is 6

1h1- Total Amount of Assessed Penalties
9 NC facilities with Assessed Penalties were not counted for FFY2012.
Total for this Metric is $104,210.00

1h2- Number of Formal Enforcement Actions with an Assessed Penalty
9 NC Formal Enforcement Actions with Assessed Penalties were not counted for FFY2012.
Total for this Metric is 14

1g4- Number of Tier II Facilities Subject to a Formal Action
6 NC Tier II Facilities Subject to a Formal Action were not counted for FFY2012.
Total for this Metric is 6

1i1 -Number of Stack Test with Passing Results There were 20 NC Facilities that had Stack Tests that were not counted with passing results in FFY2012. 
The source test action types and result code (99) for these facilities are all listed in AFS.
Total for this Metric is 206

1i5- Number of Stack Tests Observe and Reviewed There were 16 NC Facilities that were Observed and Reviewed that were not counted in FFY2012.
The source test action type (23) for these facilities are all listed in AFS.
Total for this Metric is 169

1i6 -Number of Stack Tests Reviewed Only There were 4 NC Facilities that were Reviewed Only were not counted in FFY2012.
The source test action type (TR) for these facilities are all listed in AFS.
Total for this Metric is 110
 
CWA Problems with the translation and timing of the data between EPA and the state exist for the number of active permits, enforcement actions, and facilities in Category 2 Non-Compliance. As a result, the data metrics do not reflect the complete number of activities the state performed.  
RCRA This is for info and for the understanding of NC data.

Metric 1a4, the state of North Carolina is currently looking at this universe because a lot of these facilities are out of business. 

Metric 1f2, the state North Carolina uses three additional RCRAInfo formal enforcement codes (codes) to track NC requirements. The codes are 214, 219 and 220. Code 214 is used for NC assessed investigative and inspection costs associated with the issuance of a formal enforcement action with a stipulated penalty. Code 219 is used when an informal meeting is held with a facility that has received a formal enforcement action. Code 220 is used for the issuance of an Immediate Action Notice of Violation (IANOV). An IANOV is a form of formal enforcement that is issued to address situations generally involving actual or likely exposures to hazardous waste or hazardous waste constituents that require immediate attention or to situations that pose an immediate threat to human health and the environment through improper management of solid/hazardous wastes. The IANOV establishes a formal compliance schedule of activities and may be followed by a stipulated penalty using one of the previously described enforcement responses. 

Metric 1g, a formal penalty was issued to two companies with the same name distinguished by the EPA Identification Number; the penalty was separated for entry into RCRAInfo.
 
North Dakota RCRA Metric 1b1 and 1b2 (facilities inspected and number of inspections): The inspection total numbers for 2012 include 33 US EPA Region VIII "site visits" to oil production lease sites which generate solid waste (subject to RCRA 7003 and USFW's MBTA). The inspection trend numbers should be viewed with this understanding.  
Ohio CWA This verification is submitted with acknowledgement that, while it is the based on the best review possible give the resources available, errors will still be evident. Ohio also wants to state its belief that the Quarterly SNC statistic is a better reflection of the Compliance record for the State.  
RCRA RCRARep indicates 3 EPA formal enforcement actions in Ohio. SRF data indicate 7.  
Oklahoma CAA As usual, the source universes metrics are dynamic, so these numbers change. All static metrics appear to be fine.  
CWA
  • Due to program commitments & manpower limitations, ODEQ does not code into EPA's ICIS-NPDES Production database the general & minor facility enforcement actions (metrics 1e1, 1e2, 1f1, 1f2, & 2a1), penalties (metrics 1g1 & 1g2), compliance schedules (metric 7b1), permit schedules (metric 7c1), or single-event violations (metric 7a2).
  • Stormwater facility data (metric 1a4) is not maintained in ICIS-NPDES Production, but in ODEQ's in-house database.
  • Metrics 1e1(facilities with informal actions), 1e2(total number of informal actions at CWA NPDES Facilities), 1f1 (facilities with formal actions), 1f2 (total number of formal actions at CWA facilities), 1g1 (number of enforcement actions with penalties), 1g2 (total penalties assessed), 7b1(number of facilities with compliance schedule violation), & 7c1(number of facilities with a permit schedule violation) reflect the Major facilities data only.
  • ODEQ has provided for metric 1g1 & 1g2, the penalties collected (not assessed) for the revised value in the table to the right
CWA Data Table (PDF) (1 pp, 87K, About PDF)
RCRA 1) The below listed facilities appear in metrics 1b1 & 1b2 for counting the number of total inspections. However, for unknown reasons, they do not show up in metric 5b for counting LQG coverage's.
  • JOHN ZINK COMPANY, L.L.C.-OKD987084860
  • SSM OKLAHOMA-OKD071236103
  • NOV Tuboscope dba National Oilwell Varco LP-OKD981595150
  • Kay County Hospital-OKR000026732
  • Mertz mfg. South-OKD007239775
  • Mertz mfg. North-OKR000027813

2) The facilities below were notified as LQG when the inspection was initiated but later re-notified as a different generator status, which artificially lowered our LQG inspection numbers.
  • MAGELLAN PIPELINE COMPANY, L.P OKC RENO TERMINAL- OKD981586720
  • CENTER POINT ENERGY- OKR000026518
  • Phillips 66 Glenpool South- OKD000758474
  • NATURAL GAS PIPELINE OF AMERICA - COMPRESSOR STATION # 156- OKT410010375
  • Patterson Well-OKR000027102

3) The SRF still counts the number of biennial report LQGs (168 metric 1a5) for pulling the percent coverage instead of using the active universe (134 metric 1a2). This serves to artificially lower the percent making it appear that the state is not meeting the 20% goal. Since the biennial report number includes closed facilities and/or one-time generators, it would be illogical to use that list to pull from for LQG inspection targeting. Therefore using it for SRF percent calculation is similarly illogical.

4) Our % coverage for TSDs should be 100% instead of the reported 84.6% because we have had two facilities (Systech & Tulsa Cement) notify as TSDs right before the end of our fiscal year and we therefore didn't have the opportunity to inspect them. 

5) We have changed two SNC facilities, the Shamrock CSE & Gibson CDI to FCIs. This should make them eligible to be counted for our SNC ID rate as governed by metric 8a (SNC ID rate, currently reported as 0%). It seems arbitrary that SNCs are only counted when they arise from a CEI or a FCI. We do not understand why a SNC that arises from a CSE or a CDI (or another RCRAinfo category) is not counted. A SNC is a SNC regardless of the type of evaluation that discovers it.

6) Related to number 5 above, if our SNC ID rate is 0% (according to metric 8a) how can we be timely on our SNCs (metric 8b)? The only way that we can see how that could make sense would be if the information governed by metric 8b included data from outside (before) the SRF data range, which (if true) should render it invalid for SRF purposes.
 
Pennsylvania CAA PA LCON 02
The correct number of Major/Title V facilities in Philadelphia is 35. In the OTIS report, as of March 13th, 2013, it is showing up as 40 under Metric ID numbers: 1b4 and 5e. This has been corrected in AFS. Air Management Services has completed 100% of Title V Cert. reviews and it is showing up as 85% under Metric ID 5e.

PA LCON 00
1a3: Vics Time and Keystone Heli are no longer subject to NESHAP. Deactivated in AFS, 1/30/2013.

1a4: All of these facilities have been downgraded to minor status, and their CMS schedules were removed in AFS.

1a6: Since these are minor sources, they are not required to be in CMS and, therefore, are not classified.

1j: Review indicates that there are 123 missing TV certifications. However, about half of these are Synthetic Minor facilities, which are not required to submit Title V certifications. Title V certifications are being entered for most of the remainder.
 
RCRA Any data discrepancies that might exist will be investigated and resolved in accordance with the EPA and PADEP QA/QC Data Management Plan.  
Rhode Island CWA For Clariant Corp., RIPDES permit # RI0000132, a formal enforcement action was issued on 2/24/12 with an assessed penalty of $112,200, but as of 9/30/12, the case had not settled, and as of 9/30/12, no penalty had been collected.  
RCRA RIDEM completed Compliance Evaluation Inspections at 17 LQGs during FFY'12; however only 13 appear in OTIS. RIDEM believes that the discrepancy is related to the selection of LQGs that submitted BRs during the 2009 reporting cycle. The use of BRS LQGs only effectively skews the data relating to the size and inspection coverage of the LQG universe.  
South Dakota CWA 1a3 - SD has a widget permit in ICIS that is used for copying limits to new permits as a time saver. This should not be counted in the total number. Also, Northville was switched to a general permit and are now in the process of switching back to an individual permit so they are here and have not been switched back yet.

1a4 - Any permit beginning with ND are North Dakota permits but showing up in South Dakota's data based on their address. This is an OTIS issue on how locations are being pulled.

7a2 - The permit for CR Industries was terminated in 2007 and is now showing up due to the way ICIS changed the SNC/RNC.

7g1 - The permit for CR Industries was terminated in 2007 and is now showing up due to the way ICIS changed the SNC/RNC.
 
 
Texas CAA The State of Texas has completed its review of the FY2012 SRF CAA enforcement data. The AFS extract program pulls inspection, violation and enforcement data from CCEDS and is uploaded to AFS. The data displayed in AFS is as reliable as the extract program used to pull data from CCEDS.

The number of Administrative Orders would be different between data systems. The AFS extract program was built to report enforcement information by facility. This means that a multi-facility Order in CCEDS would upload multiple times depending on the number of facilities named in the Order. This would also apply to other multi-facility enforcement actions such as referrals.

Metric ID Comments
  • 1a1 Universe includes AFS numbers assigned by EPA (3).
  • 1a2 TCEQ does not capture or maintain this information.
  • 1a3 TCEQ does not capture or maintain this information.
  • 1a4 TCEQ does not capture or maintain this information.
  • 1a5 TCEQ does not capture or maintain this information.
  • 1a6 TCEQ does not capture or maintain this information.
  • 1b4 Universe includes AFS numbers assigned by EPA (3).
  • 1c1 TCEQ Compliance and Enforcement database shows 357 FCEs at Major facilities during this time period.
  • 1c2 TCEQ Compliance and Enforcement database shows 357 FCEs at Major facilities during this time period.
  • 1c3 TCEQ does not capture or maintain this information.
  • 1c4 TCEQ does not capture or maintain this information.
  • 1d2 TCEQ does not capture or maintain this information.
  • 1f1 Number of HPV's Identified (Activity Count) (per OTIS State Review Framework Results)
    CCEDS: 130 AFS: 116
  • 1f2 Number of Facilities with an HPV Identified (Facility Count) (per OTIS State Review Framework Results)
    CCEDS: 103 AFS: 89
  • 1g1 Data manually uploaded to correct errors.
  • 1g3 TCEQ does not capture or maintain this information.
  • 1g4 TCEQ does not capture or maintain this information.
  • 1h1 Total Amount of Final Penalties: $5,236,654 (per OTIS State Review Framework Results)
    CCEDS: $5,229,708
  • 1h2 Data corrections uploaded.
  • 1i3 TCEQ does not submit pending results to AFS.
  • 1i4 TCEQ does not capture or maintain this information.
 
RCRA The Texas Commission on Environmental Quality (TCEQ) Office of Compliance and Enforcement, Central Texas Area, Program Support Section, has reviewed Metric 1b1 (number of sites inspected) and Metric 1b2 (number of inspections) as part of the 2012 Data Verification Process. Based on this review, the TCEQ submits the following data caveats:
  • RCRAInfo reflects record review inspections; however, OTIS does not reflect record review inspections. TCEQ conducted 211 record review inspections that are not reflected in OTIS.
  • TCEQ conducted 51 inspections at conditionally exempt small quantity generators and 107 industrial and hazardous waste complaint inspections that are not reflected in either RCRAInfo or OTIS. These inspections are not reflected in either RCRAInfo or OTIS because the sites do not have (and are not required to have) EPA Identification Numbers (EPA IDs). One of the criteria for an inspection to upload from TCEQ's Consolidated Compliance and Enforcement Data System (CCEDS) to RCRAInfo is an EPA ID associated to the site that was inspected. This is a requirement of RCRAInfo rather than CCEDS.
Other caveats include:
  • RCRA Enforcement Data - The number of multi-facility orders varies between the state database and RCRAInfo. The state database counts multi-facility orders as a single order. This would also apply to other multi-facility enforcement actions such as referrals.
  • Texas Commission on Environmental Quality has the following numbers for RCRA Handlers:
    LQGs = 944, SQGs = 2430, All other Active sites = 3170
 
Virginia CWA 1a3 - MD0064556, NCS000528 are not issued by Virginia.

1a4 - Virginia General Permit information is not uploaded to ICIS. Permits shown are limited to the facilities that have had federal inspections done in the past; they are a fraction of the VPDES general permits.

1b3 - DC0022004 is not issued by Virginia.

2a1 - The violation type code couldn't be entered or linked to the effluent violations for permits VA0003077 and VA0020346 due to historical DMR records being absent in ICIS. The DMR data in PCS for the previous permit version were not migrated into ICIS for linkage. 

7a1 - DC0022004 is not issued by Virginia.

7a2 - The number of Non-Major facilities with single event violations should be 46. Two violation events couldn't be entered into ICIS for VA0020745 due to history data being absent from ICIS (Data of the previous cycle were not migrated from PCS). The violation code for both events was A0011, the violation dates were 05/24/2012 and 07/18/2012.

7c1 - The permit schedule violation listed for permit VA0026891 was not a violation and has been removed.

7f1 - The count for the Non-Major facilities in Category 1 noncompliance is not accurate- 7 of the 12 listed facilities with the RNC status "Schedule Violation" in ICIS have been changed to "Resolved". The count posted on the EPA SRF or ECHO site is incomplete; it does not include any facility with effluent violation according to the SNC criteria since Virginia does not upload any Non-Major permit Discharge Monitoring Report or effluent violation data into ICIS. The accurate count of the Category 1 Noncompliance is submitted to EPA in the Annual Noncompliance Report (ANCR) every calendar year.

7g1 - The count for the Non-Major facilities in Category 2 Noncompliance is not accurate or complete. It does not include any facility with effluent violation since Virginia does not upload any Non-Major permit Discharge Monitoring Report or effluent violation data into ICIS. The accurate count of the Category 2 Noncompliance is submitted to EPA in the Annual Noncompliance Report (ANCR) every calendar year.

8a1 - VA0083135 and VA0091383 are compliant as listed in the FY12 QNCR report; they should be removed from this list. VA0092002 Greens Corner WWTP was in SNC in quarter 2, should be added to the list. Total count of facilities in SNC in FY12 should be 4.
 
RCRA For metric 1a2, Number of active LQGs, the count should be 260. Three facilities were counted as LQG that were not LQG immediately prior to or during FFY12 but became LQG after 10/1/2012:
  1. VAD070360219, Rubbermaid Commercial Products, LLC - Distribution Center, Receive Date of LQG status 10/15/12;
  2. VAD085125466, Univar USA, Inc., Receive Date of LQG status 1/14/13; and
  3. VAD982579872, Columbus Ave LLC, Receive Date of LQG status 12/21/12.
 
Washington CWA In December 2012, Washington began flowing data to ICIS-NPDES; however, the compliance history data is incomplete but expected to be corrected by the end of March 2013. As a result, SRF data will be incorrect for some facilities because it was frozen prior to the necessary data fixes. Some schedule dates may be incorrect. Some limit sets did not flow properly for a variety of reasons which may result in incorrect non-receipt or other violations. These violations could potentially cause a facility to be in significant non-compliance when in fact it is not. The public can access and search PARIS.  
RCRA Caveat for metric 1A4
Ecology data systems indicate 2,709 active sites that are not TSD, LQG, or SQG. This is a large difference when compared to the 1,733 in metric 1A4, and is likely due to the handler translation, a process which continues to be problematic. It is important to Ecology to resolve this difference, and it will be investigated further in preparation for when our handler translation issues are resolved.
 
Wisconsin CAA Data metrics 1b1, 1b2, and 1b3, cannot be accurately verified. Our data on Federally-Reportable NSPS Facilities, NESHAP Facilities and MACT Facilities are still under development; each succeeding year the data improve.  
CWA Wisconsin is still in the process of improving the uploading of data from the state permits database to EPA ICIS. Data that is currently uploaded to ICIS is limited to facility information for majors and non-major surface water dischargers; facility inspections for majors and non-majors; and DMR data for majors only. As a result, Data Metrics do not represent the more comprehensive data available in our state database, especially for compliance tracking and enforcement actions.  
Wyoming CAA 1a1 -The list of 141 state facilities include 2 that are on the Northern Arapaho Tribal Reservation plus 2 facilities have combined recently = 138. There were 145 active Major Sources in the State of Wyoming in FFY 2012. An additional 8 have been rescinded out of Title V during FFY12, and 1 has been added =138 current facilities are major.

1a3 - The state of Wyoming does not have a way to track this type of facility, therefore this metric is inaccurate and does not reflect all the applicable facilities within the State of Wyoming.

1a4, 1a5 & 1a6 - This is looking at historical information that may or may not be accurate and can not be corrected after year end.

1b1, 1b2, & 1b3 - The state of Wyoming does not have a way to track this type of facility, therefore this metric is inaccurate and does not reflect all the applicable facilities within the State of Wyoming.

1b4 - The list of 143 state facilities include 2 that are on the Northern Arapaho Tribal Reservation 2 facilities have combined recently, plus 2 facilities that should not be listed = 138. There were 145 active Major Sources in the State of Wyoming in FFY 2012. An additional 8 have been rescinded out of Title V during FFY12, and 1 has been added =138 current facilities are major.

1c1, 1c2, 1c3 & 1c4 - The WY AQD performed approximately 552 inspections throughout the state in FFY 2012, including the 96 listed in Metric 1c2. This metric does NOT capture all enforcement activity input as performed and entered by the State. There are ~351 inspection that are not accounted for in these metrics.

1e1 through 1h2 - All NOV's and HPV's are accounted for except for facilities that cannot have AFS ID's assigned to the due to not being entered into our system yet or that are for asbestos.

1i1 through 1i6 - The state of Wyoming has not been entering a majority of the stack test due to lack of manpower.

1j - The number of ACC's does not match the number of Major sources because a source is not required to submit one until its first Title V permit has been issued.
 
RCRA Wyoming Refining Co. is listed as one of the 2 facilities where formal actions were taken during the review period to properly document annual, recurring settlement expenditures/payments for a 2002 RCRA settlement where penalty and/or SEP expenditures are expected to continue through 2015. The data base can only calculate this amount as part of the total penalty amounts collected by the state per year if the actual enforcement action is entered, even though the enforcement action was resolved several years ago. Tim Link, Wyoming DEQ/SHWD  

 

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